Brown v. Commissioner
United States Tax Court
The petitioners, six airline pilots for Southern Airways, Inc., went out on strike against the airline in June 1960, and during 1960 and 1961 received strike benefit payments from their union, Air Line Pilots Association. Five of the petitioners were active members and one was an apprentice member of the association.
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The petitioners, six airline pilots for Southern Airways, Inc., went out on strike against the airline in June 1960, and during 1960 and 1961 received strike benefit payments from their union, Air Line Pilots Association. Five of the petitioners were active members and one was an apprentice member of the association. The benefits were paid pursuant to an established schedule or formula, based upon the pilot's preceding year's airline income, and were paid from assessments made by the association against member pilots of other airlines who were not engaged in any work stoppage. A minimum…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in the petitioners’ income taxes as follows:
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The respondent having conceded error with respect to one of the issues in docket No. 2659-63, the only issues remaining for decision herein are: (1) Whether strike benefit payments received by the petitioners during the taxable years in issue are includable in their gross income, and (2) whether the petitioners in docket Nos. 2562-63, 2659-63, 2660-63, and 2661-63 are liable for additions to tax for the taxable years in issue on account of negligence or intentional disregard of rules…
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
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- Commissioner v. LoBueSupreme Court of the United States · 1956
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