Osborne v. Commissioner
United States Tax Court
P1 and P2 were airline pilots who participated in a secondary strike called by ALPA, the pilots union. P1 was a member of ALPA, but P2 was not. ALPA, pursuant to its procedural rules, authorized the payment of strike benefits to striking pilots. ALPA assessed its membership to fund the benefits, and it paid out equal amounts of benefits to all striking pilots, regardless of each pilot's rank, union standing, or financial need.
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P1 and P2 were airline pilots who participated in a secondary strike called by ALPA, the pilots union. P1 was a member of ALPA, but P2 was not. ALPA, pursuant to its procedural rules, authorized the payment of strike benefits to striking pilots. ALPA assessed its membership to fund the benefits, and it paid out equal amounts of benefits to all striking pilots, regardless of each pilot's rank, union standing, or financial need. P1 and P2 each received strike benefits from ALPA. Held: Strike benefits constitute taxable income to P1 and P2.
1Opinion of the Court
RICHARD A. OSBORNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; PETER L. DAWSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Osborne v. Commissioner
Docket Nos. 8455-93, 14846-93
United States Tax Court
T.C. Memo 1995-71; 1995 Tax Ct. Memo LEXIS 72; 69 T.C.M. (CCH) 1895;
February 14, 1995, Filed
Decision will be entered under Rule 155 in docket No. 8455-93. Decision will be entered for respondent in docket No. 14846-93.
P1 and P2 were airline pilots who participated in a secondary strike called by ALPA, the pilots union. P1 was a member of ALPA, but P2 was not. ALPA,…
2Cases cited34 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- United States v. WhiteSupreme Court of the United States · 1944
- United Mine Workers v. Coronado Coal Co.Supreme Court of the United States · 1922
- Commissioner v. LoBueSupreme Court of the United States · 1956
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