Webber v. Commissioner
United States Tax Court
1. Income or Gifts -- Solicited Contributions of Listeners to Religious Radio Programs -- Sec. 22 (a), I. R. C. -- The petitioners, in putting on religious radio programs, were conducting a business for profit, and amounts designated for them by name received from listeners following solicitations for funds were income to the petitioners from their business rather than nontaxable gifts. 2. Gross Income -- Sec. 275 (c), I. R. C. -- Statute of Limitations. -- The Commissioner…
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1. Income or Gifts -- Solicited Contributions of Listeners to Religious Radio Programs -- Sec. 22 (a), I. R. C. -- The petitioners, in putting on religious radio programs, were conducting a business for profit, and amounts designated for them by name received from listeners following solicitations for funds were income to the petitioners from their business rather than nontaxable gifts. 2. Gross Income -- Sec. 275 (c), I. R. C. -- Statute of Limitations. -- The Commissioner has failed to show that amounts contributed by listeners to religious radio programs designated for support of those…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies in income tax as follows:
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The issues for decision are (1) whether a portion of the amounts received from radio listeners were gifts rather than taxable income and (2) whether the statute of limitations barred assessment of any of the deficiencies.
The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioners, husband and wife, residing in Oklahoma, filed their returns with the collector of internal revenue for the district of Oklahoma. Those were separate returns for…
2Cases cited8 opinions
- Reis v. CommissionerUnited States Tax Court · 1942
- Sullenger v. CommissionerUnited States Tax Court · 1948
- Sutor v. CommissionerUnited States Tax Court · 1951
- Bass v. HawleyCourt of Appeals for the Fifth Circuit · 1933
- Poorman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Walker v. CommissionerUnited States Tax Court · 1966
- Edward F. Webber v. Commissioner or Internal Revenue, Edward F. Webber and Lelia Vesta Webber v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Rhombar Co. v. CommissionerUnited States Tax Court · 1966
- Publishers New Press, Inc. v. CommissionerUnited States Tax Court · 1964
11 more not listed; retrieve them via the Exa API.