Legal Opinion

Fritschle v. Commissioner

United States Tax Court

Decided July 27, 1982No. Docket No. 134-81PublishedCited by 8 opinions

Petitioner-wife received payments for work done in assembling ribbons and rosettes. A large portion of that work was performed by petitioners' eight children living at home.

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Petitioner-wife received payments for work done in assembling ribbons and rosettes. A large portion of that work was performed by petitioners' eight children living at home. Held, notwithstanding that part of the work was performed by the children, all such payments are included in petitioners' gross income under sec. 61, I.R.C. 1954, and that result is not changed by sec. 73, I.R.C. 1954. Held, further, petitioners are allowed an offsetting deduction for payments received by petitioner-husband as reimbursement for employee business expenses. Held, further, petitioners are entitled to a…

1Opinion of the Court

Fay, Judge:

Respondent determined deficiencies in and additions to petitioners’ Federal income tax as follows:

Addition to tax

Year Deficiency sec. 6653(b)1

1975 $1,173.40 $586.70

1976 1,809.97 904.99

1977 200.00 0

After concessions,2 the remaining issues are (1) whether payments received in 1975,1976, and 1977 by petitioner Helen R. Fritschle for assembling ribbons and rosettes are includable in petitioners’ gross income; (2) whether certain payments received in 1975 and 1976 by petitioner Robert T. Fritschle are deductible reimbursed employee expenses; (3) whether petitioners are entitled to a…

2Cases cited19 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Corliss v. BowersSupreme Court of the United States · 1930
  4. Harrison v. SchaffnerSupreme Court of the United States · 1941
  5. Burnet v. LeiningerSupreme Court of the United States · 1932

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

3Cited by8 opinions

  1. Tobler v. DerwinskiUnited States Court of Appeals for Veterans Claims · 1991
  2. Bassett v. CommissionerUnited States Tax Court · 1993
  3. Lopez v. Comm'rUnited States Tax Court · 2017
  4. Bassett v. CommissionerUnited States Tax Court · 1993
  5. Brian D. Ray & Betsy Ray v. CommissionerUnited States Tax Court · 2018

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

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