Green v. Commissioner
United States Tax Court
Petitioner possesses a rare type of blood. Thus, her blood plasma is a rare commodity which is profitably processed and marketed by others who are willing to pay "donors" for the plasma. Petitioner has sold her blood plasma for a number of years, including 1976, as her primary source of funds. As a seller of blood plasma, petitioner devotes constant attention to her diet and made 95 "donations" in 1976 for which she was paid by the pint.
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Petitioner possesses a rare type of blood. Thus, her blood plasma is a rare commodity which is profitably processed and marketed by others who are willing to pay "donors" for the plasma. Petitioner has sold her blood plasma for a number of years, including 1976, as her primary source of funds. As a seller of blood plasma, petitioner devotes constant attention to her diet and made 95 "donations" in 1976 for which she was paid by the pint. Held, the payments received by petitioner for her plasma "donations" were income received in her trade or business of selling the product of blood plasma:…
1Opinion of the Court
Margaret Cramer Green, Petitioner v. Commissioner of Internal Revenue, Respondent
Green v. Commissioner
Docket No. 6183-78
United States Tax Court
74 T.C. 1229; 1980 U.S. Tax Ct. LEXIS 64; 74 T.C. No. 90;
September 15, 1980, Filed
Decision will be entered under Rule 155.
Petitioner possesses a rare type of blood. Thus, her blood plasma is a rare commodity which is profitably processed and marketed by others who are willing to pay "donors" for the plasma. Petitioner has sold her blood plasma for a number of years, including 1976, as her primary source of funds. As a seller of blood plasma, petitioner…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
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