Placko v. Commissioner
United States Tax Court
Held, payments petitioner received from a union during 1976 were includable in his gross income in that year rather than excludable as gifts under sec. 102, I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined a deficiency of $2,010 in petitioner’s 1976 Federal income tax. The sole issue is whether payments received by petitioner from the Northwest Airlines Master Executive Council of the Air Line Pilots Association during 1976 were excludable from gross income as gifts under section 102.1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioner Jerry S. Placko and Linda A. Placko, husband and wife, timely filed a joint Federal income tax return for 1976. They resided at Richfield, Minn., when petitioner timely filed his petition…
2Cases cited7 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- United States v. KaiserSupreme Court of the United States · 1960
- Brown v. CommissionerUnited States Tax Court · 1967
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Gregory v. United StatesDistrict Court, E.D. North Carolina · 1986
- Abdella v. CommissionerUnited States Tax Court · 1983
- Osborne v. CommissionerUnited States Tax Court · 1995
- Placko v. CommissionerUnited States Tax Court · 1980
- Stone v. CommissionerUnited States Tax Court · 1985
2 more not listed; retrieve them via the Exa API.