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MILLER v. COMMISSIONER

Docket Nos. 94574, 94575.

39 T.C. 505 (1962)

KATHERINE F. MILLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOSEPH M. DE TOTA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 7, 1962.

Attorney(s) appearing for the Case

Charles S. Wilcox, Esq., for the petitioners.

Colin C. MacDonald, Jr., Esq., for the respondent.

OPINION.

HOYT, Judge:

The respondent determined deficiencies in petitioner Miller's income taxes for the years 1957, 1958, and 1959 of $94.19, $111.04, and $121.68, respectively. For the same years petitioner De Tota's deficiencies were determined to be $116.27, $122.18, and $119.33, respectively. The issue for decision is whether distributions from a Christmas fund to employees of a membership club were income to the recipients within the meaning...

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