Trujillo v. Commissioner
United States Tax Court
TASK Corp., the employer of the petitioner-husband, withheld 1 percent of the first $ 9,000 of wages paid to petitioner during the calendar year 1975 pursuant to secs. 984-986, California Unemployment Insurance Code. Such withholdings at the source constituted compulsory contributions to the California State Unemployment Compensation Disability Fund.
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TASK Corp., the employer of the petitioner-husband, withheld 1 percent of the first $ 9,000 of wages paid to petitioner during the calendar year 1975 pursuant to secs. 984-986, California Unemployment Insurance Code. Such withholdings at the source constituted compulsory contributions to the California State Unemployment Compensation Disability Fund. Held: 1. The compulsory "contribution" made in 1975 by petitioner to the California disability insurance fund is deductible as a State "income" tax within the purview of sec. 164(a)(3), I.R.C. 1954. McGowan v. Commissioner, 67 T.C. 599 (1976),…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency of $22.78 in petitioners’ Federal income tax for the calendar year 1975.
This matter is before the Court on a motion for summary judgment filed by petitioners April 7, 1977, pursuant to the provisions of Rule 121, Tax Court Rules of Practice and Procedure. The parties agreed to submit the motion for decision without oral argument. Accordingly, respondent filed his original brief on May 31, 1977. Petitioners filed a statement with the Court on June 2, 1977, adopting the position taken in the amicus curiae brief filed on that date.…
2Cases cited6 opinions
- Geduldig v. AielloSupreme Court of the United States · 1974
- McGowan v. CommissionerUnited States Tax Court · 1976
- Cox v. CommissionerUnited States Tax Court · 1963
- Stewart v. State of CaliforniaCalifornia Court of Appeal · 1969
- People v. WarfelCalifornia Court of Appeal · 1958
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Fife v. CommissionerUnited States Tax Court · 1980
- Elizabeth Jackson Simpson & Geoffrey N. Simpson v. CommissionerUnited States Tax Court · 2019
- Fife v. CommissionerUnited States Tax Court · 1980
- Trujillo v. CommissionerUnited States Tax Court · 1977