United States Tax Court September 17, 1986, Docket No. 5384-83 (Foley v. Commissioner)

James M. Foley, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent Foley v. Commissioner Docket No. 5384-83 United States Tax Court 87 T.C. 605; 1986 U.S. Tax Ct. LEXIS 51; 87 T.C. No. 35; September 17, 1986, Filed *51 Decision will be entered under Rule 155. Petitioner, a U.S. citizen, resided and worked in West Berlin, Germany. He received incentive payments pursuant to art.