409 F2d 1359 Ferrer v. Commissioner of Internal Revenue

409 F.2d 1359

Jose V. FERRER, Petitioner-Appellant,

No. 527.

Docket 32888.

United States Court of Appeals Second Circuit.

Argued May 20, 1969.

Decided May 20, 1969.

Appeal from decision of Tax Court finding a tax deficiency for the year 1962 on the grounds that petitioner had not established that he was a bona fide resident of a foreign country or countries under § 911(a) (1) of the Internal Revenue Code of 1954.

Timothy P. Walsh, New York City (Hardin, Hess, Eder & Rashap, New York City, on the brief), for petitioner-appellant.

Benjamin M. Parker, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Crombie J. D. Garrett, Attys., Department of Justice, on the brief), for respondent-appellee.

Before LUMBARD, Chief Judge, FEINBERG, Circuit Judge, and TIMBERS, District Judge.*


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We affirm in open court the decision of the Tax Court reported at 50 T.C. No. 19 (1968), which held that Jose V. Ferrer was not a bona fide resident of a foreign country or countries during the calendar year 1962, as provided by Section 911(a) (1), Internal Revenue Code of 1954, so as to avoid liability for income taxes, and determined a deficiency of $122,840.18 after allowing certain deductions for unreimbursed business expenses and disallowing other such claimed expenses.



Sitting by designation