Jones v. Commissioner
United States Court of Appeals for the Fifth Circuit
927 F.2d 849 (1991)

- Written by Alex Ruskell, JD
Facts
George Jones (plaintiff) was employed by International Air Service Company, Ltd. (International). International based Jones in Japan. Jones planned to stay in Japan until his retirement. However, Jones’s wife kept a house in Anchorage, where she worked at a bank. Jones lived in a hotel in Japan for convenience and cost issues. Jones and his wife tried to see each other as frequently as possible, but Jones had to pay for the trips. Jones remained in Japan for many years. During that time, Jones returned a dividend sent to him by the State of Alaska based on his having Alaskan residence, and he filed taxes in Japan. On his United States tax forms, he took a § 911 exclusion, which allows taxpayers to exclude from their gross income all or part of their income earned in another country, based on his claim that he was a bona fide Japanese resident. The tax commissioner (defendant) claimed that the exclusion was invalid because Jones was a United States resident and issued a notice of tax deficiency. Jones sued, and the court ruled in the commissioner’s favor. Jones appealed.
Rule of Law
Issue
Holding and Reasoning (Goldberg, J.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.