Legal Opinion

Benningfield v. Commissioner

United States Tax Court

Decided September 19, 1983No. Docket No. 5057-82Published

On Dec. 25, 1979, P purported to assign or sell indefinitely "accounts receivable" representing his wages, to PTS, purportedly a trust. PTS purported to "resell" P's "accounts" to IDI, "requesting" that IDI contribute 90 percent or more of these accounts to "non-profit organizations." In 1979, P endorsed two paychecks from his employer to PTS.

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On Dec. 25, 1979, P purported to assign or sell indefinitely "accounts receivable" representing his wages, to PTS, purportedly a trust. PTS purported to "resell" P's "accounts" to IDI, "requesting" that IDI contribute 90 percent or more of these accounts to "non-profit organizations." In 1979, P endorsed two paychecks from his employer to PTS. The same day, C, purportedly a Canadian charitable trust, issued to P checks denominated as "gifts" and equaling 92 percent of the paychecks P had just endorsed to PTS. On his 1979 tax return, P excluded from income the full amount of the two paychecks…

1Opinion of the Court

Max Eugene Benningfield, Jr., and Shelley Jean Benningfield, Petitioners v. Commissioner of Internal Revenue, Respondent

Benningfield v. Commissioner

Docket No. 5057-82

United States Tax Court

81 T.C. 408; 1983 U.S. Tax Ct. LEXIS 40; 81 T.C. No. 27;

September 19, 1983, Filed

Decision will be entered under Rule 155.

On Dec. 25, 1979, P purported to assign or sell indefinitely "accounts receivable" representing his wages, to PTS, purportedly a trust. PTS purported to "resell" P's "accounts" to IDI, "requesting" that IDI contribute 90 percent or more of these accounts to "non-profit organizations." In…

2Cases cited38 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Lucas v. EarlSupreme Court of the United States · 1930
  4. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  5. Bixby v. CommissionerUnited States Tax Court · 1972

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