United States Tax Court
64 T.C. 245 (1975)
In 1969, Stephen Pulsifer, Susan Pulsifer, and Thomas Pulsifer (plaintiffs) won the Irish Hospital Sweepstakes (Sweepstakes). Because the Pulsifers were minor children, their winnings were deposited with an Irish court in an interest-bearing account. The money could not be released until the children turned 21 years old or until an application to the Irish court was made on the children’s behalf by their legal representative. In a later year, the Pulsifers’ father petitioned the Irish court for the release of the children’s winnings. The federal tax commissioner (commissioner) (defendant) determined a deficiency for the Pulsifers for the 1969 tax year, holding that the children’s winnings should have been included in their gross income for that year. The Pulsifers petitioned the United States Tax Court for a redetermination, arguing that their winnings should instead be taxed in the year that they received the money.
Rule of Law
Holding and Reasoning (Hall, J.)
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