Denniston v. Commissioner
United States Tax Court
The petitioner, in his capacity as an employee of the General Services Administration of the U.S. Government, was the chairman and executive director of a task force which obtained reductions in rates charged for certain communication services and thereby accomplished substantial savings to the Government. The members of this task force, including the petitioner, received cash awards for superior accomplishment under the Government Employees' Incentive Awards Act.
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The petitioner, in his capacity as an employee of the General Services Administration of the U.S. Government, was the chairman and executive director of a task force which obtained reductions in rates charged for certain communication services and thereby accomplished substantial savings to the Government. The members of this task force, including the petitioner, received cash awards for superior accomplishment under the Government Employees' Incentive Awards Act. Held, that the cash award received by the petitioner constituted additional compensation for services rendered, taxable to him…
1Opinion of the Court
OPINION
The sole issue is whether the award received by the petitioner in the taxable year 1959 under the Government Employees’ Incentive Awards Act constituted taxable income to him.
The petitioner contends that the award was essentially a gift and comes within the specific exclusion from gross income provided in section 74(b) of the Internal Revenue Code of 1954.3 It is his position that the award was made primarily in recognition of some achievement referred to in that section (apparently civic achievement), that he was selected without any action on his part to enter the contest or…
2Cases cited7 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Harrison v. Northern Trust Co.Supreme Court of the United States · 1943
- Carasso v. CommissionerUnited States Tax Court · 1960
- Max and Fannie Carasso v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Evans v. CommissionerUnited States Tax Court · 1967
- Mt. Mansfield Co. v. CommissionerUnited States Tax Court · 1968
- Beausoleil v. CommissionerUnited States Tax Court · 1976
- Francis M. Rogallo and Gertrude S. Rogallo v. United StatesCourt of Appeals for the Fourth Circuit · 1973
- Robert and Barbara Jones v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
11 more not listed; retrieve them via the Exa API.