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COLWELL v. COMMISSIONER

Docket No. 342-73.

64 T.C. 584 (1975)

MADONNA J. AND JAMES E. COLWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 17, 1975.

Attorney(s) appearing for the Case

James E. Colwell, pro se.

Edward B. Simpson, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' income tax for the year 1970 in the amount of $1,164.12. The sole issue presented for our decision is whether certain benefits paid to James E. Colwell during a strike against his employer constitute gifts within the meaning of section 102(a)1 and are therefore excludable from petitioners' gross income.

FINDINGS...

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