Legal Opinion

Reid v. Commissioner

United States Tax Court

Decided August 7, 1989No. Docket No. 878-88UnpublishedCited by 2 opinions

During 1979 and 1980, petitioner was the payee of several checks issued by Quality Labs. Petitioner endorsed these checks and gave them to her husband, a physician, who either deposited the checks or cashed them. Petitioner at no time performed any services for Quality Labs. Held: The proceeds of such checks are not income to petitioner; although petitioner derived some benefit from such proceeds, she was not their true earner.

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During 1979 and 1980, petitioner was the payee of several checks issued by Quality Labs. Petitioner endorsed these checks and gave them to her husband, a physician, who either deposited the checks or cashed them. Petitioner at no time performed any services for Quality Labs. Held: The proceeds of such checks are not income to petitioner; although petitioner derived some benefit from such proceeds, she was not their true earner. Neither was petitioner an active participant or essential element in any kickback scheme which might involve her husband and Quality Labs. Held further: Petitioner is…

1Opinion of the Court

SALATHEA REID, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Reid v. Commissioner

Docket No. 878-88

United States Tax Court

T.C. Memo 1989-407; 1989 Tax Ct. Memo LEXIS 405; 57 T.C.M. (CCH) 1211; T.C.M. (RIA) 89407;

August 7, 1989

During 1979 and 1980, petitioner was the payee of several checks issued by Quality Labs. Petitioner endorsed these checks and gave them to her husband, a physician, who either deposited the checks or cashed them. Petitioner at no time performed any services for Quality Labs. Held: The proceeds of such checks are not income to petitioner; although petitioner…

2Cases cited3 opinions

  1. Commissioner v. WilcoxSupreme Court of the United States · 1946
  2. Lashells' Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
  3. Brittingham v. CommissionerUnited States Tax Court · 1971

3Cited by2 opinions

  1. ArouthUnited States Tax Court · 1992
  2. Keith A. Bolles & Shelley R. Bolles v. CommissionerUnited States Tax Court · 2019

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