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
Bruce, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the year 1976 of $577 as set forth .in his statutory notice of deficiency dated April 17, 1978. The issues presented1 for our decision all involve whether petitioner is entitled to business-expense deductions relative to her activity as a blood plasma donor in excess of those allowed by respondent. Petitioner claimed as business-expense deductions amounts allegedly spent for medical insurance premiums, special drugs, high protein diet foods, and transportation to and from the laboratory where petitioner…
2Cases cited38 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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3Cited by17 opinions
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- Perez v. CommissionerUnited States Tax Court · 2015
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