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Revenue Ruling 61-136

1961-2 C.B. 20 (1961)

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Revenue Ruling 61-136

Internal Revenue Service
1961-2 C.B. 20 (1961)

JR

Facts

In United States v. Kaiser, a labor union provided room rent and food vouchers to Kaiser, a needy non-union member participating in the strike. When the characterization of those payments was challenged in a jury trial, the jurors considered the type and amount of benefits provided, Kaiser’s personal need and lack of other income, and whether Kaiser could receive public assistance. Based on those factors, the jurors determined that the strike benefits did qualify as gifts under Internal Revenue Code of 1954 § 102(a) and should not be included in Kaiser’s gross income. The United States Supreme Court affirmed that verdict.

Rule of Law

Issue

Holding and Reasoning ()

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