Holt v. Commissioner
United States Tax Court
Petitioner Bentley, a noncompetent ward of the Federal Government and a tribal Indian, raised cattle on tribal lands by authority of a permit issued by the tribe. He had acquired the cattle with a loan obtained pursuant to a "rehabilitation" program operated by the tribe for its members through a grant by the Federal Government. Petitioner disposed of the cattle in 1958 and contended that the income derived therefrom was exempt from Federal income taxation.
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Petitioner Bentley, a noncompetent ward of the Federal Government and a tribal Indian, raised cattle on tribal lands by authority of a permit issued by the tribe. He had acquired the cattle with a loan obtained pursuant to a "rehabilitation" program operated by the tribe for its members through a grant by the Federal Government. Petitioner disposed of the cattle in 1958 and contended that the income derived therefrom was exempt from Federal income taxation. Held, the absence of any provision in a treaty or Act of Congress exempting from taxation income so derived results in its taxation.…
1Opinion of the Court
Bentley L. Holt and Bonnie J. Holt, Petitioners, v. Commissioner of Internal Revenue, Respondent
Holt v. Commissioner
Docket Nos. 86329, 93475
United States Tax Court
44 T.C. 686; 1965 U.S. Tax Ct. LEXIS 46;
July 30, 1965, Filed
Decisions will be entered under Rule 50.
Petitioner Bentley, a noncompetent ward of the Federal Government and a tribal Indian, raised cattle on tribal lands by authority of a permit issued by the tribe. He had acquired the cattle with a loan obtained pursuant to a "rehabilitation" program operated by the tribe for its members through a grant by the Federal Government.…
2Cases cited14 opinions
- United States v. RickertSupreme Court of the United States · 1903
- Squire v. CapoemanSupreme Court of the United States · 1956
- Choteau v. BurnetSupreme Court of the United States · 1931
- Superintendent of Five Civilized Tribes v. CommissionerSupreme Court of the United States · 1935
- Commissioner of Internal Revenue v. Freeman P. Walker and Bernice WalkerCourt of Appeals for the Ninth Circuit · 1964
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