Beausoleil v. Commissioner
United States Tax Court
Held, a $ 1,600 Invention Achievement Award received by petitioner from his employer was additional compensation taxable as ordinary income under sec. 61(a)(1), I.R.C. 1954, and not a payment in consideration of the transfer of invention rights taxable as capital gain under sec. 1235, I.R.C. 1954.
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency of $320.37 in petitioners’ Federal income tax for 1972. Petitioners have conceded the correctness of two of the adjustments made by respondent in the computation of their 1972 income tax, and a single issue remains for decision: Whether $1,600 received by petitioner William F. Beausoleil from his employer, International Business Machines, Inc., as an Invention Achievement Award, is taxable as ordinary income under section 611 or as capital gain under section 1235.
FINDINGS OF FACT
Petitioners William F. and Florence M. Beausoleil were legal…
2Cases cited11 opinions
- United States v. Dubilier Condenser CorpSupreme Court of the United States · 1933
- Blum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
- Hofferbert, Collector of Internal Revenue v. BriggsCourt of Appeals for the Fourth Circuit · 1949
- Chilton v. CommissionerUnited States Tax Court · 1963
- Downs v. Comm'rUnited States Tax Court · 1968
6 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Ofria v. CommissionerUnited States Tax Court · 1981
- Boulez v. CommissionerUnited States Tax Court · 1984
- Herbert S. And Arlene S. Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1987
- Schulze v. Comm'rUnited States Tax Court · 1980
- Beausoleil v. CommissionerUnited States Tax Court · 1976
5 more not listed; retrieve them via the Exa API.