Felman v. Commissioner
United States Tax Court
In 1963 petitioner became entitled to, and received, readjustment pay in the amount of $ 12,600 under the provisions of the Act of June 28, 1962, Pub. L. 87-509, 87th Cong., 1st Sess., 76 Stat. 120, 50 U.S.C. sec. 1016. Held, the amount so received was includable in petitioner's gross income under sec. 61 (a), I.R.C. 1954, and was not excludable therefrom under sec. 113, I.R.C. 1954.
1Opinion of the Court
OPINION
In substance, this case is controlled by our decision in Leland W. Woolard, 47 T.C. 274. The petitioner in that case in 1962 became entitled to and received readjustment pay in the amount of $12,300 under the provisions of Pub. L. 87-509, because he was involuntarily released from active duty as a Reserve officer in the U.S. Air Force on June 30, 1962, after completion of approximately 16 years of service. The only difference in principle between the facts in petitioner’s case and Woolard’s case is that petitioner did. not reenlist, whereas Woolard did reenlist. Because Woolard…
2Cases cited7 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Woolard v. CommissionerUnited States Tax Court · 1966
- Donahoe v. CommissionerUnited States Tax Court · 1954
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3Cited by7 opinions
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- Berger v. CommissionerUnited States Tax Court · 1981
- Felman v. CommissionerUnited States Tax Court · 1968
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