Hornung v. Commissioner
United States Tax Court
1. Held, the value of a Corvette automobile which was awarded to petitioner for being named the outstanding player in the 1961 National Football League championship game constituted gross income under sec. 74, I.R.C. 1954, in the year of receipt, 1962. 2. Held, further, the value of the free use of Thunderbird automobiles furnished to the petitioner by the Ford Motor Co. was not received as the result of a tax-exempt gift; and, under the particular facts of the case, an…
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1. Held, the value of a Corvette automobile which was awarded to petitioner for being named the outstanding player in the 1961 National Football League championship game constituted gross income under sec. 74, I.R.C. 1954, in the year of receipt, 1962. 2. Held, further, the value of the free use of Thunderbird automobiles furnished to the petitioner by the Ford Motor Co. was not received as the result of a tax-exempt gift; and, under the particular facts of the case, an economic benefit was realized which constituted gross income. Petitioner has failed to carry his burden of proof that…
1Opinion of the Court
Hoyt, Judge:
Respondent determined an income tax deficiency against petitioner in the amount of $3,163.76 for the taxable year 1962. Petitioner having conceded an issue relating to a travel expense deduction, the questions remaining for decision are:(1) Whether the value of a 1962 Corvette automobile which was won by petitioner for his performance in a professional football game should be included in his gross income for the taxable year 1962.(2) Whether the value of the use of 1962 Thunderbird automobiles furnished to the petitioner by the Ford Motor Co. should 'be included in his gross…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Malat v. RiddellSupreme Court of the United States · 1966
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
6 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Maurice M. Wills and Gertrude E. Wills v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1969
- Wills v. CommissionerUnited States Tax Court · 1967
- Pascarelli v. CommissionerUnited States Tax Court · 1971
- In Re United Air Lines, Inc., Debtor. U.S. Bank National Association, Cross-Appellee v. United Air Lines, Inc., Debtor-AppelleeCourt of Appeals for the Seventh Circuit · 2006
- Veterans of Foreign Wars, Dep't of Michigan v. CommissionerUnited States Tax Court · 1987
28 more not listed; retrieve them via the Exa API.