Legal Opinion

Dobra v. Commissioner

United States Tax Court

Decided December 29, 1998No. Tax Ct. Dkt. No. 7573-97Published

H and W owned four residential properties located in State O. One of the properties was H and W's family residence. The other three were not. H and W used the properties to provide residential care for adults. State O paid H and W for this care. H and W did not report any of the payments received from State O in 1992 and 1993, on the theory that the payments were "qualified foster care payments", excluded from gross income under sec. 131(a), I.R.C.

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H and W owned four residential properties located in State O. One of the properties was H and W's family residence. The other three were not. H and W used the properties to provide residential care for adults. State O paid H and W for this care. H and W did not report any of the payments received from State O in 1992 and 1993, on the theory that the payments were "qualified foster care payments", excluded from gross income under sec. 131(a), I.R.C. None of the unreported payments were "difficulty of care payments", as defined by sec. 131(c), I.R.C. HELD: To be excluded from gross income under…

1Opinion of the Court

PAVEL DOBRA AND ANA DOBRA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Dobra v. Commissioner

Tax Ct. Dkt. No. 7573-97

United States Tax Court

111 T.C. 339; 1998 U.S. Tax Ct. LEXIS 55; 111 T.C. No. 19;

December 29, 1998, Filed

Decision will be entered for respondent.

H and W owned four residential properties located in State O. One of the properties was H and W's family residence. The other three were not. H and W used the properties to provide residential care for adults. State O paid H and W for this care. H and W did not report any of the payments received from State O in 1992 and…

2Cases cited23 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  3. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  4. Richards v. United StatesSupreme Court of the United States · 1962
  5. Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982

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