Legal Opinion

Gallery v. Commissioner

United States Tax Court

Decided November 17, 1971No. Docket No. 6408-69SCPublished

In 1966 petitioner enrolled as a junior in the College of Engineering at the University of Detroit in Michigan. The university made available to students, including petitioner, the opportunity to be employed by Ford Motor Co. in the latter's "College Cooperative Program" which afforded students the opportunity to test career interests and aptitudes on major assignments closely related to their college major in preparation for a potential career with Ford or another firm.

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In 1966 petitioner enrolled as a junior in the College of Engineering at the University of Detroit in Michigan. The university made available to students, including petitioner, the opportunity to be employed by Ford Motor Co. in the latter's "College Cooperative Program" which afforded students the opportunity to test career interests and aptitudes on major assignments closely related to their college major in preparation for a potential career with Ford or another firm. Petitioner participated in this program and in April 1967 he concluded his first cooperative work period at Ford's Buffalo,…

1Opinion of the Court

Thomas W. and Jennifer A. Gallery, Petitioners v. Commissioner of Internal Revenue, Respondent

Gallery v. Commissioner

Docket No. 6408-69SC

United States Tax Court

57 T.C. 257; 1971 U.S. Tax Ct. LEXIS 26;

November 17, 1971, Filed

Decision will be entered for the respondent.

In 1966 petitioner enrolled as a junior in the College of Engineering at the University of Detroit in Michigan. The university made available to students, including petitioner, the opportunity to be employed by Ford Motor Co. in the latter's "College Cooperative Program" which afforded students the opportunity to test career…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Fischer v. CommissionerUnited States Tax Court · 1968
  3. Weiszmann v. CommissionerUnited States Tax Court · 1969
  4. Carroll v. CommissionerUnited States Tax Court · 1968
  5. Ronald F. Weiszmann and Deborah C. Weiszmann v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971

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