William H. Adair and Patricia Adair - Page 1

                                        T.C. Memo. 1995-493                                             

                                     UNITED STATES TAX COURT                                            

                    WILLIAM H. ADAIR AND PATRICIA ADAIR, Petitioners v.                                 
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 5731-93.                Filed October 12, 1995.                            

                        Pursuant to the U.S. Code, U.S. employees may be                                
                  either detailed or transferred to international                                       
                  organizations for foreign service.  P was transferred                                 
                  from the U.S. Army to NATO.  For years after 1981, sec.                               
                  911, I.R.C., was amended to exclude from the definition                               
                  of foreign earned income amounts "paid by the United                                  
                  States or an agency thereof to an employee of the                                     
                  United States or an agency thereof".  Held:  P was an                                 
                  employee of NATO, and not an employee of the United                                   

                  Daniel Harvey FitzGibbon, for petitioners.                                            
                  Brian M. Harrington, for respondent.                                                  

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