Jackson v. Commissioner
United States Tax Court
The Motion Picture Association of America, Inc., paid the sum of $ 38,270 to Stephen S. Jackson, upon the termination of his employment at the request of members of the association. The payment was made pursuant to Jackson's suggestion, and after he had executed a general release of all claims against the association, its officers, and members. It was charged by the association on its books of account to salary expense.
Read the full summary
The Motion Picture Association of America, Inc., paid the sum of $ 38,270 to Stephen S. Jackson, upon the termination of his employment at the request of members of the association. The payment was made pursuant to Jackson's suggestion, and after he had executed a general release of all claims against the association, its officers, and members. It was charged by the association on its books of account to salary expense. Held, that said amount was subject to income tax under section 22 (a) of the Internal Revenue Code (1939), and was not a gift exempt under section 22 (b) (3).
1Opinion of the Court
Ruth Jackson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Stephen S. Jackson, Petitioner, v. Commissioner of Internal Revenue, Respondent
Jackson v. Commissioner
Docket Nos. 48567, 48568
United States Tax Court
25 T.C. 1106; 1956 U.S. Tax Ct. LEXIS 257;
February 29, 1956, Filed
Decisions will be entered for the respondent.
The Motion Picture Association of America, Inc., paid the sum of $ 38,270 to Stephen S. Jackson, upon the termination of his employment at the request of members of the association. The payment was made pursuant to Jackson's suggestion, and after he had executed a…
2Cases cited15 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Noel v. ParrottCourt of Appeals for the Fourth Circuit · 1926
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
10 more not listed; retrieve them via the Exa API.