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Turner v. Commissioner

United States Tax Court

13 T.C.M. 462 (1954)

Relevant factsFree

Mr. Turner won a nontransferable, restriction-laden pair of first-class cruise tickets in a radio contest, reported $520 as their value on his tax return, and separately negotiated with the cruise company to exchange them for four tourist-class tickets so his whole family (plaintiffs) could travel; the Commissioner (defendant) issued a deficiency notice valuing the tickets at their full $2,200 retail price, and the Turners petitioned the Tax Court for review.

IssueFree

Whether, for purposes of federal tax law, the value of a noncash benefit is the value actually realized by the taxpayer and not the retail price.

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