Legal Opinion

Huff v. Commissioner

United States Tax Court

Decided April 26, 1983No. Docket Nos. 10902-77, 10903-77, 10954-77PublishedCited by 28 opinions

Petitioner-husbands were employees of B, a corporation. A California court imposed civil penalties on B and other civil penalties on petitioner-husbands and other employees of B, for which petitioner-husbands and the other were severally liable.

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Petitioner-husbands were employees of B, a corporation. A California court imposed civil penalties on B and other civil penalties on petitioner-husbands and other employees of B, for which petitioner-husbands and the other were severally liable. Held: 1. B's payments of the civil penalties imposed on petitioner-husbands resulted in gross income taxable to petitioners. 2. Since these civil penalties were imposed in order to punish petitioner-husbands for violating State law, sec. 162(f), I.R.C. 1954, bars any deduction otherwise allowable under sec. 162(a), I.R.C. 1954.

1Opinion of the Court

Chabot, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1973 as follows:

Docket No. Deficiency

Larry D. Huff and Darlene Huff . 10902-77 $31,552

E. James Rohn and Judith M. Rohn . 10903-77 28,430

John R. and Louise R. Wolfe . 10954-77 22,950

These cases have been consolidated for trial, briefs, and opinion. The parties have settled most of the adjustments made in the notices of deficiency. The issues remaining for decision are as follows:(1) Whether, under section 61(a),2 the payments by Bestline Products, Inc., of civil penalties imposed on…

2Cases cited37 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  3. Helvering v. CliffordSupreme Court of the United States · 1940
  4. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  5. Commissioner v. HeiningerSupreme Court of the United States · 1943

32 more not listed; retrieve them via the Exa API.

3Cited by28 opinions

  1. O'Malley v. CommissionerUnited States Tax Court · 1988
  2. William E. Bailey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
  3. Barone v. CommissionerUnited States Tax Court · 1985
  4. Jon T. Stephens and Susanne Stephens v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
  5. Talley Industries Inc. Consolidated Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997

23 more not listed; retrieve them via the Exa API.

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