green
Positive treatment
2.6 score
Treatment trajectory · 1962 → 2026 · click a year to view as-of
1962
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Top citers, strongest first. 1 distinct citer.
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Cited as authority (rule)
Commissioner of IRS v. Estate of Travis L. Sanders
See also Jones v. Comm’r, 927 F.2d 849, 854-55 (5th Cir. 1991) (observing that “[a] taxpayer’s intent plays perhaps the most important part in determining the establishment and maintenance of a foreign residence,” but then proceeding to consider a number of objective factors as evidence of the taxpayer’s residence); Moore v. United States, 289 F.2d 926, 926-27 (5th Cir. 1961) (explaining that the “decision whether [an] American national is exempt from federal income tax by reason of being a bona fide resident of a foreign country depends upon the peculiar factors touching on his re…
Retrieving the full opinion text from the archive…
F. A. MOORE and Wife Julia F. Moore, Appellants,
v.
UNITED STATES of America, Appellee
v.
UNITED STATES of America, Appellee
18608_1.
Court of Appeals for the Fifth Circuit.
May 9, 1961.
Robert L. Schwarz, Howard J. Stafford, Jr., Stafford, Atlas & Spilman, McAllen, Tex., for appellants., William A. Friedlander, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., William B. Butler, U. S. Atty., Houston, Tex., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., I. Henry Kutz, Lloyd J. Keno, Attys., Dept. of Justice, Washington, D. C., for appellee.
Tuttle, Hutcheson, Brown.
Cited by 3 opinions | Published
PER CURIAM.
It appearing that the decision whether an American national is exempt from federal income tax by reason of being a bona fide resident of a foreign country depends upon the peculiar facts touching on his relationships with both the foreign and the domestic scene, and it appearing[*927] that the facts in this case fully warrant the finding against the claim of such bona fide residence by appellants made by the trial court, the judgment of that Court is hereby affirmed on the basis of the written opinion in 180 F.Supp. 483.