Heidel v. Commissioner
United States Tax Court
1. Held, value of Southeastern Conference grant-in-aid athletic scholarship did not constitute support furnished by petitioner for himself in 1961 within the meaning of sec. 1303(c)(1), I.R.C. 1954. 2. Held, petitioner failed to prove that $ 50,000 bonus received by him from St. Louis Football Cardinals in 1965 when he signed contract to play professional football for them was income attributable to work performed by petitioner in substantial part during two or more of the…
Read the full summary
1. Held, value of Southeastern Conference grant-in-aid athletic scholarship did not constitute support furnished by petitioner for himself in 1961 within the meaning of sec. 1303(c)(1), I.R.C. 1954. 2. Held, petitioner failed to prove that $ 50,000 bonus received by him from St. Louis Football Cardinals in 1965 when he signed contract to play professional football for them was income attributable to work performed by petitioner in substantial part during two or more of the base period years 1961 through 1964 within the purview of sec. 1303(c)(2)(B), I.R.C. 1954. 3. Held, petitioner was not an…
1Opinion of the Court
James B. Heidel and Joanna P. Heidel, Petitioners v. Commissioner of Internal Revenue, Respondent
Heidel v. Commissioner
Docket No. 5405-68
United States Tax Court
56 T.C. 95; 1971 U.S. Tax Ct. LEXIS 148;
April 20, 1971, Filed
Decision will be entered for the respondent.
1. Held, value of Southeastern Conference grant-in-aid athletic scholarship did not constitute support furnished by petitioner for himself in 1961 within the meaning of sec. 1303(c)(1), I.R.C. 1954.
2. Held, petitioner failed to prove that $ 50,000 bonus received by him from St. Louis Football Cardinals in 1965 when he signed…
2Cases cited5 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- H. G. And Frances Kellam Hendricks v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Heidel v. CommissionerUnited States Tax Court · 1971
- Van Hook v. United StatesCourt of Appeals for the Seventh Circuit · 1953
- Wilson v. United StatesDistrict Court, D. Kansas · 1971