Legal Opinion

Tyler v. Commissioner

United States Tax Court

Decided August 10, 1949No. Docket No. 17875Published

In 1942 petitioner, a pilot employed by United Air Lines in Seattle, accepted employment with a firm in Cleveland, which employment was thought at first to be temporary but continued until November 1, 1946. Petitioner's former employer from time to time from 1942 to May 1944 granted petitioner leaves of absence in order that he might retain his seniority rights as a pilot with United.

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In 1942 petitioner, a pilot employed by United Air Lines in Seattle, accepted employment with a firm in Cleveland, which employment was thought at first to be temporary but continued until November 1, 1946. Petitioner's former employer from time to time from 1942 to May 1944 granted petitioner leaves of absence in order that he might retain his seniority rights as a pilot with United. On March 30, 1945, petitioner's wife left him, taking with her various assets, including U. S. savings bonds jointly owned by petitioner and his wife and valued at $ 14,325. Held: (1) That the petitioner's…

1Opinion of the Court

Grover Tyler, Petitioner, v. Commissioner of Internal Revenue, Respondent

Tyler v. Commissioner

Docket No. 17875

United States Tax Court

13 T.C. 186; 1949 U.S. Tax Ct. LEXIS 112;

August 10, 1949, Promulgated

Decision will be entered under Rule 50.

In 1942 petitioner, a pilot employed by United Air Lines in Seattle, accepted employment with a firm in Cleveland, which employment was thought at first to be temporary but continued until November 1, 1946. Petitioner's former employer from time to time from 1942 to May 1944 granted petitioner leaves of absence in order that he might retain his seniority…

2Cases cited5 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. O'Hara v. CommissionerUnited States Tax Court · 1946
  3. Bark v. CommissionerUnited States Tax Court · 1946
  4. Chapman v. CommissionerUnited States Tax Court · 1947
  5. Tyler v. CommissionerUnited States Tax Court · 1949

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