Frederick W. Denniston v. Commissioner of Internal Revenue

Petitioners, a husband and wife filing a joint income tax return, seek reversal of a Tax Court determination that moneys the husband received as a Government Employees’ Incentive Award were includible in gross income. We affirm, adopting the decision of the Tax Court.

The excellent services which led to the award in question were just those which the husband had been instructed to perform in the course of his employment. The statute under which the award to him was made does not authorize awards for “religious, charitable, scientific, educational, artistic, literary, or civic achievement” (26…