Bannon v. Commissioner
United States Tax Court
During 1986, P received payments from the State of California to provide nonmedical care to her totally disabled adult daughter pursuant to the State's in-home supportive services program. P did not report these payments as income on her 1986 Federal income tax return. R determined that the payments are includable in gross income under sec. 61 as compensation for services.
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During 1986, P received payments from the State of California to provide nonmedical care to her totally disabled adult daughter pursuant to the State's in-home supportive services program. P did not report these payments as income on her 1986 Federal income tax return. R determined that the payments are includable in gross income under sec. 61 as compensation for services. P contends that the payments were made in the public interest and constitute nontaxable welfare benefits. Held: Under California law, P's daughter was the welfare recipient under the program and was "intended to be the…
1Opinion of the Court
Dorothy E. Bannon, Petitioner v. Commissioner of Internal Revenue, Respondent
Bannon v. Commissioner
Docket No. 26900-90
United States Tax Court
99 T.C. 59; 1992 U.S. Tax Ct. LEXIS 56; 99 T.C. No. 3;
July 20, 1992, Filed
Decision will be entered for respondent.
During 1986, P received payments from the State of California to provide nonmedical care to her totally disabled adult daughter pursuant to the State's in-home supportive services program. P did not report these payments as income on her 1986 Federal income tax return. R determined that the payments are includable in gross income under sec.…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- United Housing Foundation, Inc. v. FormanSupreme Court of the United States · 1975
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Graff v. CommissionerUnited States Tax Court · 1980
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