Legal Opinion

Briggs v. Commissioner

United States Tax Court

Decided December 30, 1980No. Docket Nos. 1473-78, 5978-78Published

Ps paid dues to a labor union. Some of the dues were allocated by the union to a building fund and to a fund for the construction of recreation centers for the union members. In return for the dues allocated to the building fund, Ps received certificates which were equal in face amount to the dues so allocated and which were redeemable under specified conditions.

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Ps paid dues to a labor union. Some of the dues were allocated by the union to a building fund and to a fund for the construction of recreation centers for the union members. In return for the dues allocated to the building fund, Ps received certificates which were equal in face amount to the dues so allocated and which were redeemable under specified conditions. Held: 1. The dues allocated to the building fund were not ordinary and necessary expenses under sec. 162, I.R.C. 1954, since Ps received the redeemable certificates; and 2. The dues allocated to recreation centers were personal…

1Opinion of the Court

Carl and Ruth Briggs, Petitioners v. Commissioner of Internal Revenue, Respondent; Raymond J. Hurbi, Petitioner v. Commissioner of Internal Revenue, Respondent

Briggs v. Commissioner

Docket Nos. 1473-78, 5978-78

United States Tax Court

75 T.C. 465; 1980 U.S. Tax Ct. LEXIS 4;

December 30, 1980, Filed

Decisions will be entered for the respondent.

Ps paid dues to a labor union. Some of the dues were allocated by the union to a building fund and to a fund for the construction of recreation centers for the union members. In return for the dues allocated to the building fund, Ps received certificates…

2Cases cited23 opinions

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. Sanford v. CommissionerUnited States Tax Court · 1968
  3. William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
  4. Primuth v. CommissionerUnited States Tax Court · 1970
  5. Carroll v. CommissionerUnited States Tax Court · 1968

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