Legal Opinion

Raffensperger v. Commissioner

United States Tax Court

Decided March 31, 1960No. Docket No. 69160PublishedCited by 13 opinions

The Union Club of Tokyo was a nonappropriated fund activity established and operated under Army regulations and as such was an agency of the United States during the year 1953, and the salary paid to petitioner as civilian manager thereof was not excludible from his gross income under section 116(a), I.R.C. 1939.

1Opinion of the Court

Drennen, Judge:

Respondent determined a deficiency in petitioners’ income tax for the calendar year 1953 in the amount of $2,572.84. Petitioners claim an overpayment of income tax for the same year in the sum of $2,265.96.

The first issue, whether a proper notice of deficiency was mailed to petitioners prior to the expiration of the statute of limitations as provided by section 6501(a), I.R.C. 1954, has been conceded by petitioners on reply brief.

The only remaining issue is whether the salary paid to petitioner Frank E. Raffensperger by the Union Club of Tokyo as its manager during 1953 was…

2Cases cited4 opinions

  1. Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
  2. Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
  3. Teskey v. CommissionerUnited States Tax Court · 1958
  4. Sverdrup v. CommissionerUnited States Tax Court · 1950

3Cited by13 opinions

  1. Matthews v. CommissionerUnited States Tax Court · 1989
  2. Donaldson v. CommissionerUnited States Tax Court · 1969
  3. Arnold A. Morse, Sr., and Hellen v. Morse v. The United StatesUnited States Court of Claims · 1971
  4. McComish v. CommissionerUnited States Tax Court · 1975
  5. Boleslaw D. Kalinski and Dorothy M. Kalinski v. Commissioner of Internal Revenue, Carol Marie Schmidt v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1976

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