Martin v. Commissioner
United States Tax Court
Petitioners were Conrail employees who lost their jobs in 1982 as a result of enactment of the Northeast Rail Service Act (NERSA). They received benefits under the employee protection provisions enacted as part of NERSA. Held, such benefits are includable in gross income under sec. 61(a), I.R.C. 1954. Held, further, such benefits are not unemployment compensation within the meaning of sec. 85, I.R.C. 1954.
1Opinion of the Court
John Roberts Martin and Shirley Mae Martin, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Martin v. Commissioner
Docket Nos. 42605-85, 2334-86, 35620-86
United States Tax Court
90 T.C. 1078; 1988 U.S. Tax Ct. LEXIS 72; 90 T.C. No. 72;
May 24, 1988. May 24, 1988, Filed
Decisions will be entered for the respondent.
Petitioners were Conrail employees who lost their jobs in 1982 as a result of enactment of the Northeast Rail Service Act (NERSA). They received benefits under the employee protection provisions enacted as part of NERSA. Held, such benefits are includable in gross…
Also in this document: Dissent.
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
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