Martin v. Commissioner
United States Tax Court
Petitioners were Conrail employees who lost their jobs in 1982 as a result of enactment of the Northeast Rail Service Act (NERSA). They received benefits under the employee protection provisions enacted as part of NERSA. Held, such benefits are includable in gross income under sec. 61(a), I.R.C. 1954. Held, further, such benefits are not unemployment compensation within the meaning of sec. 85, I.R.C. 1954.
1Opinion of the Court
OPINION
TANNENWALD, Judge:
Respondent determined the following deficiencies iri petitioners’ Federal income taxes:
Petitioners Year Deficiency
John Roberts Martin and 1982 $806
Shirley Mae Martin 1983 423
Bernard J. Spanski and Margaret L. Spanski 1982 3,393
After concessions by petitioners, the issues for decision are: (1) Whether certain payments to Mr. Martin and Mr. Spanski made under title VII of the Regional Rail Reorganization Act of 19732 (3R Act) as amended by the Northeast Rail Service Act of 19813 (NERSA), are includable in gross income under section 614 or are exempt from taxation under…
2Cases cited10 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Lilly v. CommissionerSupreme Court of the United States · 1952
- McGowan v. CommissionerUnited States Tax Court · 1976
- Beggy v. CommissionerUnited States Tax Court · 1955
5 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Mearkle v. CommissionerUnited States Tax Court · 1988
- John Roberts Martin Shirley Mae Martin Bernard J. Spanski and Margaret L. Spanski v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Sutherland v. EggerCourt of Appeals for the Third Circuit · 1989
- Slattery v. United StatesUnited States Court of Claims · 1988
- Sutherland v. EggerCourt of Appeals for the Third Circuit · 1989
10 more not listed; retrieve them via the Exa API.