Legal Opinion

Cloud v. Commissioner

United States Tax Court

Decided December 9, 1991No. Docket Nos. 14973-88, 31425-88, 8297-89Published

P, an active member of the Democratic Party, was appointed a deputy registrar of the State Bureau of Motor Vehicles in Butler County, Ohio. Deputy registrars operated the State's license bureaus, which charged customers for processing driver's license applications, vehicle registrations, license plates, and license tabs. Deputy registrars in Ohio were appointed pursuant to annual contracts with the Registrar.

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P, an active member of the Democratic Party, was appointed a deputy registrar of the State Bureau of Motor Vehicles in Butler County, Ohio. Deputy registrars operated the State's license bureaus, which charged customers for processing driver's license applications, vehicle registrations, license plates, and license tabs. Deputy registrars in Ohio were appointed pursuant to annual contracts with the Registrar. In order to obtain the appointment and ensure renewal of his contract in following years, P was required to obtain the recommendation of the Democratic Party. In order to get that…

1Opinion of the Court

DOUGLAS CLOUD AND PEGGY CLOUD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cloud v. Commissioner

Docket Nos. 14973-88, 31425-88, 8297-89

United States Tax Court

97 T.C. 613; 1991 U.S. Tax Ct. LEXIS 105; 97 T.C. No. 43;

December 9, 1991, Filed

Decisions will be entered under Rule 155.

P, an active member of the Democratic Party, was appointed a deputy registrar of the State Bureau of Motor Vehicles in Butler County, Ohio. Deputy registrars operated the State's license bureaus, which charged customers for processing driver's license applications, vehicle registrations, license plates,…

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Bixby v. CommissionerUnited States Tax Court · 1972
  5. Commissioner v. TellierSupreme Court of the United States · 1966

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