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Jose v. Ferrer v. Commissioner of Internal Revenue , 409 F.2d 1359 ( 1969 )


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  • 409 F.2d 1359

    69-1 USTC P 9425

    Jose V. FERRER, Petitioner-Appellant,
    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

    No. 527, Docket 32888.

    United States Court of Appeals Second Circuit.

    Argued May 20, 1969.
    Decided May 20, 1969.

    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.1

    PER CURIAM:

    1

    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.

    1

    Sitting by designation