Sykes v. Commissioner
United States Tax Court
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
OPINION.
Rattm, Judge:
Section 74 of the Internal Revenue Code of 1954 treats all prizes and awards, with certain exceptions not material here, as taxable income. These provisions, however, are prospective only, and it remains for the courts to attempt to apply the principles recognized under earlier law with respect to prior years. At times, some rather fine lines have been drawn, and in Ray W. Campeau, 24 T. C. 370, we undertook an analysis of some of the decisions in this field.
The present controversy, in our opinion, falls within the line of cases characterized by Max Silver, 42 B. T. A.…
2Cases cited5 opinions
- Washburn v. CommissionerUnited States Tax Court · 1945
- 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
- Reynolds v. United StatesDistrict Court, N.D. California · 1954
- Campeau v. CommissionerUnited States Tax Court · 1955
- Bates v. GlennDistrict Court, W.D. Kentucky · 1953
3Cited by2 opinions
- Neal v. CommissionerUnited States Tax Court · 1988
- Sykes v. CommissionerUnited States Tax Court · 1955