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Turner v. Commissioner

13 T.C.M. (CCH) 462, T.C. Memo 1954-38 (1954)

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Turner v. Commissioner

United States Tax Court

13 T.C.M. (CCH) 462, T.C. Memo 1954-38 (1954)

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Facts

Mr. and Mrs. Turner (plaintiffs) filed joint income-tax returns that included, as part of the Turners’ gross income, $520 to represent the value that the Turners ascribed to a pair of first-class cruise tickets awarded to Mr. Turner in a radio contest. The pair of cruise tickets was nontransferable and was subject to expiration and certain other restrictions. Mr. Turner had negotiated with the cruise company to exchange the two first-class tickets for four tourist-class tickets to a different destination, enabling the Turners to bring their two sons along on the cruise. The commissioner for the Bureau of Internal Revenue (defendant) issued a deficiency notice, holding that the value of the pair of tickets was $2,200, which was the retail price. The Turners petitioned the United States Tax Court for a determination.

Rule of Law

Issue

Holding and Reasoning

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