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