Graves v. Commissioner
United States Tax Court
In 1981, 1982, and 1983, petitioners received payments from the United States under the Water Bank Program, 16 U.S.C. sec. 1301 et seq., pursuant to an agreement entered into in 1978. Held, payments may be excludable from income as "grants made after September 30, 1979," even if made under a contract entered into prior to that date.
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In 1981, 1982, and 1983, petitioners received payments from the United States under the Water Bank Program, 16 U.S.C. sec. 1301 et seq., pursuant to an agreement entered into in 1978. Held, payments may be excludable from income as "grants made after September 30, 1979," even if made under a contract entered into prior to that date. Sec. 126(a)(3), I.R.C. 1954. Held, however, that petitioners failed to prove that payments in question were excludable under sec. 126(a)(3), I.R.C. 1954. Held, further, petitioners failed to prove that the expense of maintaining a guard dog was deductible as a…
1Opinion of the Court
OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1981, 1982, and 1983 in the amounts of $12,886.58, $14,351.28, and $15,703.37, respectively. After concessions, the issues for determination are (1) whether payments received by petitioners under the Water Bank Program, 16 U.S.C. sec. 1301 et seq., are excludable from income under section 126(a)(3)1 when received under a contract entered into prior to the effective date of section 126; (2) whether petitioners have proven that the payments received by them are otherwise excludable under section…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- Reisman v. CaplinSupreme Court of the United States · 1964
- Dixon v. United StatesSupreme Court of the United States · 1965
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3Cited by16 opinions
- Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
- Miller v. CommissionerUnited States Tax Court · 1989
- Dobra v. CommissionerUnited States Tax Court · 1998
- Graves v. CommissionerUnited States Tax Court · 1987
- Gates v. CommissionerUnited States Tax Court · 2010
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