Charles v. Commissioner
United States Tax Court
Petitioner, an Alaskan native, received $ 21,000 for the sale of land which the Bureau of Indian Affairs (BIA) oversees for Alaskan natives. Petitioner's funds were held by BIA for 10 days, and then distributed to petitioners. Respondent concedes the $ 21,000 is not income to petitioner. During the 10 days BIA held the $ 21,000, it was invested in a BIA account. The Interior Department Supplemental Appropriations Act, Pub.
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Petitioner, an Alaskan native, received $ 21,000 for the sale of land which the Bureau of Indian Affairs (BIA) oversees for Alaskan natives. Petitioner's funds were held by BIA for 10 days, and then distributed to petitioners. Respondent concedes the $ 21,000 is not income to petitioner. During the 10 days BIA held the $ 21,000, it was invested in a BIA account. The Interior Department Supplemental Appropriations Act, Pub. L. 97-257, 96 Stat. 818 (1982), directed BIA to distribute the funds in certain BIA accounts. Accordingly, because of petitioner's $ 21,000 sale of land, BIA made an…
1Opinion of the Court
CARL A. AND VIRGINIA CHARLES, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Charles v. Commissioner
Docket No. 16858-89
United States Tax Court
T.C. Memo 1991-635; 1991 Tax Ct. Memo LEXIS 683; 62 T.C.M. (CCH) 1582; T.C.M. (RIA) 91635;
December 23, 1991, Filed
Decision will be entered under Rule 155.
Petitioner, an Alaskan native, received $ 21,000 for the sale of land which the Bureau of Indian Affairs (BIA) oversees for Alaskan natives. Petitioner's funds were held by BIA for 10 days, and then distributed to petitioners. Respondent concedes the $ 21,000 is not income to petitioner.
Dur…
2Cases cited10 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Robertson v. United StatesSupreme Court of the United States · 1952
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