Pulsifer v. Commissioner

The Pulsifer children (plaintiffs) won the Irish Hospital Sweepstakes in 1969, but as minors their winnings were deposited in an interest-bearing account with an Irish court, inaccessible until they turned 21 or their legal representative successfully petitioned for release, which their father later did; the Commissioner (defendant) determined the winnings were taxable in 1969, the year of the deposit, rather than the later year of actual receipt, and the Pulsifers petitioned the Tax Court for redetermination.