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Filler v. Commissioner
United States Tax Court
74 T.C. 406 (1980)
- Written by Alex Ruskell, JD
Facts
Herbert Filler (plaintiff) was a bona fide resident of France. In 1972 and 1973, Filler spent five days each year in the United States on business, resulting in just over $2,000 in U.S. source compensation for those 10 days. It was undisputed that Filler paid French taxes on all of his income, which included the income allocated to business in the United States. The commissioner (defendant) recomputed Filler’s taxes for 1972 and 1973 and reduced Filler’s foreign tax credit for the $2,000. Filler sued in the United States tax court, arguing that the United States-France Income Tax Protocol, a tax treaty, controlled and entitled him to a higher foreign tax credit.
Rule of Law
Issue
Holding and Reasoning (Raum, J.)
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