Kralstein v. Commissioner
United States Tax Court
1. Petitioners received $ 60,916.15 (in cash and personal property) in 1956 in connection with a testimonial dinner given in honor of petitioner husband as vice president of the Bakery and Confectionery Workers' of America International Union. The funds used for this purpose were furnished by many persons, corporations, and business organizations whose motives and intentions in respect thereto were not uniform.
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1. Petitioners received $ 60,916.15 (in cash and personal property) in 1956 in connection with a testimonial dinner given in honor of petitioner husband as vice president of the Bakery and Confectionery Workers' of America International Union. The funds used for this purpose were furnished by many persons, corporations, and business organizations whose motives and intentions in respect thereto were not uniform. Held: $ 12,000 of the amount received is excludible from gross income as a "gift." The remainder did not constitute a gift and is not excludible from gross income. Sec. 102(a), I.R.C.…
1Opinion of the Court
OPINION.
Raum, Judge:
1. In 1956 petitioner Max Kralstein was vice president of the Bakery and Confectionery Workers’ of America International Union. On June 23, 1956, between 1,300 and 1,400 persons gathered at the Waldorf-Astoria Hotel in New York City for a testimonial dinner in his honor, sponsored by local 3 of the international union. As a result of ticket sales to this testimonal dinner and payments received for placing names in a souvenir journal published in conjunction with the dinner, a total of $85,470 was collected. After the payment of all expenses, the balance of $60,916.15 was…
2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Silverman v. CommissionerUnited States Tax Court · 1957
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- United States v. William J. ScottCourt of Appeals for the Seventh Circuit · 1982
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
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