Heidel v. Commissioner
United States Tax Court
1. Held, value of Southeastern Conference grant-in-aid athletic scholarship did not constitute support furnished by petitioner for himself in 1961 within the meaning of sec. 1303(c)(1), I.R.C. 1954. 2. Held, petitioner failed to prove that $ 50,000 bonus received by him from St. Louis Football Cardinals in 1965 when he signed contract to play professional football for them was income attributable to work performed by petitioner in substantial part during two or more of the…
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1. Held, value of Southeastern Conference grant-in-aid athletic scholarship did not constitute support furnished by petitioner for himself in 1961 within the meaning of sec. 1303(c)(1), I.R.C. 1954. 2. Held, petitioner failed to prove that $ 50,000 bonus received by him from St. Louis Football Cardinals in 1965 when he signed contract to play professional football for them was income attributable to work performed by petitioner in substantial part during two or more of the base period years 1961 through 1964 within the purview of sec. 1303(c)(2)(B), I.R.C. 1954. 3. Held, petitioner was not an…
1Opinion of the Court
DeeNNEN, Judge:
Respondent determined a deficiency of $9,628 in petitioners’ Federal income tax for the taxable year 1965.
The only issue for our decision is whether petitioner James B. Heidel (hereinafter referred to as petitioner) was an “eligible individual” in 1965 within the meaning of section 1303, I.R.C. 1954,1 thereby entitling him to the benefit of income averaging under sections 1301 through 1305. Our determination of that issue in turn depends upon whether (1) the value of a Southeastern Conference grant-in-aid athletic scholarship received by petitioner constitutes support furnished…
2Cases cited4 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- H. G. And Frances Kellam Hendricks v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Van Hook v. United StatesCourt of Appeals for the Seventh Circuit · 1953
- Wilson v. United StatesDistrict Court, D. Kansas · 1971
3Cited by12 opinions
- Baldwin v. CommissionerUnited States Tax Court · 1985
- Sharvy v. CommissionerUnited States Tax Court · 1977
- Frost v. CommissionerUnited States Tax Court · 1974
- Richard Sharvy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
- Jolitz v. CommissionerUnited States Tax Court · 1980
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