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AMARAL v. COMMISSIONER

Docket No. 9947-85.

90 T.C. 802 (1988)

ARTHUR A. AMARAL AND LUCETTE M. AMARAL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 26, 1988.

Attorney(s) appearing for the Case

Matt E. Eqqer, Richard H. Gordin, Bruce S. Lane, and Jack M. Feder, for the petitioners.

Kristine A. Roth, for the respondent.

OPINION

RUWE, Judge:*

Respondent determined deficiencies in petitioners' 1980 and 1981 Federal income taxes in the amounts of $24,180.06 and $18,976.10, respectively. The sole issue for decision is whether the salary and emoluments paid to petitioner,1 Arthur Amaral, by the North Atlantic Treaty Organization in consideration for the performance of services are exempt from taxation by the United...

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