Newman v. Commissioner
United States Tax Court
Held: Interest credited to amounts withheld from the salary of petitioner Paul Newman by the State of New York under the laws of New York providing for retirement payments to employees of the State was not interest on the obligations of a State within the meaning of sec. 103(a)(1), I.R.C. 1954. The amounts of interest credited to the account of petitioner Paul Newman were not constructively received by him in the years when they were credited since during those years he…
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Held: Interest credited to amounts withheld from the salary of petitioner Paul Newman by the State of New York under the laws of New York providing for retirement payments to employees of the State was not interest on the obligations of a State within the meaning of sec. 103(a)(1), I.R.C. 1954. The amounts of interest credited to the account of petitioner Paul Newman were not constructively received by him in the years when they were credited since during those years he could have received the amounts only by resigning from his position and withdrawing all amounts he had contributed under the…
1Opinion of the Court
Paul Newman and Helen Newman, Petitioners v. Commissioner of Internal Revenue, Respondent
Newman v. Commissioner
Docket No. 506-75
United States Tax Court
68 T.C. 433; 1977 U.S. Tax Ct. LEXIS 90;
June 29, 1977, Filed
Decision will be entered for the respondent.
Held: Interest credited to amounts withheld from the salary of petitioner Paul Newman by the State of New York under the laws of New York providing for retirement payments to employees of the State was not interest on the obligations of a State within the meaning of sec. 103(a)(1), I.R.C. 1954. The amounts of interest credited to the account…
2Cases cited19 opinions
- Birnbaum v. New York State Teachers Retirement SystemNew York Court of Appeals · 1958
- Glassman v. GlassmanNew York Court of Appeals · 1956
- Sgaglione v. LevittNew York Court of Appeals · 1975
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
- Taylor v. CommissionerUnited States Tax Court · 1943
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