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Ferrer v. Commissioner of Internal Revenue

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT


decided: May 20, 1969.

JOSE V. FERRER, PETITIONER-APPELLANT,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE

Lumbard, Chief Judge, Feinberg, Circuit Judge, and Timbers, District Judge.*fn*

Author: Per Curiam

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.


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