Legal Opinion

Sykes v. Commissioner

United States Tax Court

Decided September 30, 1955No. Docket No. 51063Published

One of the petitioners was invited to attend an annual function of a club. A portion of the program consisted of a drawing for prizes, the grand prize consisting of a new automobile. Petitioner received a ticket entitling him to attend the function and participate in every part of the program scheduled. Petitioner did not pay for such ticket, but a member of the club, his host, had paid for it. At the drawing, petitioner won the grand prize.

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One of the petitioners was invited to attend an annual function of a club. A portion of the program consisted of a drawing for prizes, the grand prize consisting of a new automobile. Petitioner received a ticket entitling him to attend the function and participate in every part of the program scheduled. Petitioner did not pay for such ticket, but a member of the club, his host, had paid for it. At the drawing, petitioner won the grand prize. Held, since a consideration had been paid for the right of petitioner to participate in the drawing, he realized income measured by the fair market value…

1Opinion of the Court

Clewell Sykes and Katherine N. Sykes, Petitioners, v. Commissioner of Internal Revenue, Respondent

Sykes v. Commissioner

Docket No. 51063

United States Tax Court

24 T.C. 1156; 1955 U.S. Tax Ct. LEXIS 86;

September 30, 1955, Filed

Decision will be entered for the respondent.

One of the petitioners was invited to attend an annual function of a club. A portion of the program consisted of a drawing for prizes, the grand prize consisting of a new automobile. Petitioner received a ticket entitling him to attend the function and participate in every part of the program scheduled. Petitioner did not pay for…

2Cases cited6 opinions

  1. Washburn v. CommissionerUnited States Tax Court · 1945
  2. Seldon R. Glenn, Collector of Internal Revenue for the District of Kentucky v. Theo W. And Mary Louise BatesCourt of Appeals for the Sixth Circuit · 1954
  3. Reynolds v. United StatesDistrict Court, N.D. California · 1954
  4. Campeau v. CommissionerUnited States Tax Court · 1955
  5. Bates v. GlennDistrict Court, W.D. Kentucky · 1953

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