Briggs v. Commissioner
United States Tax Court
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
OPINION
Simpson, Judge:
The Commissioner determined a deficiency of $306.87 in the Federal income tax of Carl and Ruth Briggs for 1975 and a deficiency of $298.05 in the Federal income tax of Raymond J. Hurbi for 1976. The only issue to be decided is whether the petitioners were entitled to deduct under section 162(a) of the Internal Revenue Code of 19541 the entire amounts of the dues paid to a labor union when some of such dues were allocated by the union to a building fund for which the members received redeemable certificates and to a fund for the construction of recreational facilities for…
2Cases cited22 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Primuth v. CommissionerUnited States Tax Court · 1970
- Carroll v. CommissionerUnited States Tax Court · 1968
17 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Tobler v. DerwinskiUnited States Court of Appeals for Veterans Claims · 1991
- Ridder v. CommissionerUnited States Tax Court · 1981
- Carl & Ruth Briggs and Raymond J. Hurbi v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Briggs v. CommissionerUnited States Tax Court · 1980
- Henao v. Comm'rUnited States Tax Court · 2016
1 more not listed; retrieve them via the Exa API.