Legal Opinion

Robillard v. Commissioner

United States Tax Court

Decided March 13, 1961No. Docket No. 80130PublishedCited by 3 opinions

Petitioner, an employee of the Tennessee Coal & Iron Division of the United States Steel Corporation, received in 1957 additional wages for work done in 1955 and 1956 which were in excess of 15 percent of his gross income in 1957. The additional wages were paid pursuant to the provisions of agreements between the corporation and the union representing employees of the corporation.

Read the full summary

Petitioner, an employee of the Tennessee Coal & Iron Division of the United States Steel Corporation, received in 1957 additional wages for work done in 1955 and 1956 which were in excess of 15 percent of his gross income in 1957. The additional wages were paid pursuant to the provisions of agreements between the corporation and the union representing employees of the corporation. The delay in payment was occasioned by failure of the corporation and the union to reach agreement as to description and classification of 90 percent of the jobs as required by agreements of June 30, 1955, and…

1Opinion of the Court

Scott, Judge:

The Commissioner determined a deficiency of $231.36 in petitioners’ income tax for the calendar year 1957. The deficiency results from the determination of the Commissioner that the amount of $1,972.62 received by petitioners in the year 1957 and reported by them as backpay does not qualify as such under the provisions of section 1303 of the Internal Revenue Code of 1954.

FINDINGS OF FACT.

Some of the facts have been stipulated and are found accordingly.

Petitioners are husband and wife, residing in Bessemer, Alabama. They filed their joint Federal income tax return for the calendar…

2Cases cited8 opinions

  1. Kenny v. CommissionerUnited States Tax Court · 1945
  2. Cowan v. Henslee, Collector of Internal Revenue. Klein v. Henslee, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
  3. Thompson Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
  4. Sedlack v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
  5. Dean v. CommissionerUnited States Tax Court · 1948

3 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Commissioner of Internal Revenue v. Joseph G. R. Robillard and Margaret H. RobillardCourt of Appeals for the Fifth Circuit · 1962
  2. Commissioner of Internal Revenue v. Joseph G. R. Robillard and Margaret H. RobillardCourt of Appeals for the Fifth Circuit · 1962
  3. Robillard v. CommissionerUnited States Tax Court · 1961

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API