Legal Opinion

Colwell v. Commissioner

United States Tax Court

Decided July 17, 1975No. Docket No. 342-73Published

Petitioner was not a member of the striking union, yet he honored its picket line and received from it regular payments, calculated as a percentage of his wages but without regard to his financial status or need and with no restrictions on use. Held, such payments were not gifts, excludable under sec. 102(a), I.R.C. 1954.

1Opinion of the Court

Madonna J. and James E. Colwell, Petitioners v. Commissioner of Internal Revenue, Respondent

Colwell v. Commissioner

Docket No. 342-73

United States Tax Court

64 T.C. 584; 1975 U.S. Tax Ct. LEXIS 111;

July 17, 1975, Filed

Decision will be entered for the respondent.

Petitioner was not a member of the striking union, yet he honored its picket line and received from it regular payments, calculated as a percentage of his wages but without regard to his financial status or need and with no restrictions on use. Held, such payments were not gifts, excludable under sec. 102(a), I.R.C. 1954.

James E.…

2Cases cited10 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. Bogardus v. CommissionerSupreme Court of the United States · 1937
  4. United States v. KaiserSupreme Court of the United States · 1960
  5. Brown v. CommissionerUnited States Tax Court · 1967

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