Drysdale v. Comm'r of Internal Revenue

4 Citing cases

  1. Anastasio v. Comm'r of Internal Revenue

    67 T.C. 814 (U.S.T.C. 1977)   Cited 3 times

    Since we rest our decision herein on the economic benefit theory, we have no need to consider whether we will follow the reversal of our decision in Harris. The cases of Drysdale v. Commissioner, 277 F.2d 413 (6th Cir. 1960), revg. 32 T.C. 378 (1959), and Aaron Watson, T.C. Memo. 1974-63, also relied upon by petitioner, similarly involved the doctrine of constructive receipt and are, therefore, distinguishable. We think that the foregoing rationale in respect of the prize money is equally applicable to the interest earned in 1970.

  2. Frost v. Comm'r of Internal Revenue

    52 T.C. 89 (U.S.T.C. 1969)   Cited 7 times

    Petitioner in his original brief contends that, as a cash basis taxpayer, the premiums on the three policies for the 3 years in question totaling $5,365.58 were not actually or constructively received by him in the taxable years, and should not, therefore, be included in his income, citing section 451(a), I.R.C. 1954; Rev. Rul. 68-99, 1968-1 C.B. 193; Cowden v. Commissioner, 289 F.2d 20 (C.A. 5, 1961), reversing and remanding 32 T.C. 853; Drysdale v. Commissioner, 277 F.2d 413 (C.A. 6, 1960), reversing and remanding 32 T.C. 378; and E. T. Sproull, 16 T.C. 244, affirmed per curiam 194 F.2d 541 (C.A. 6, 1952). Petitioner's reliance on section 451(a), supra, is misplaced.

  3. Willits v. Comm'r of Internal Revenue

    50 T.C. 602 (U.S.T.C. 1968)   Cited 3 times

    Ray S. Robinson, 44 T.C. 20, 36. Cf. Commissioner v. Oates, 207 F.2d 711 (C.A. 7), affirming 18 T.C. 570, nonacq. 1952-2 C.B. 5 withdrawn and acq. substituted 1960-1 C.B. 5; Drysdale v. Commissioner, 277 F.2d 413 (C.A. 6), reversing 32 T.C. 378; Commissioner v. Olmsted Incorporated Life Agency, 304 F.2d 16 (C.A. 8), affirming 35 T.C. 429; Kay Kimbell, 41 B.T.A. 940, acq. 1940-2 C.B. 5. The issue before us is whether the 1960 and 1961 corpus commissions here in controversy fall on the side of the line controlled by the first group of cases or whether they are on the other side governed by the second group of cases.

  4. Zeltzerman v. Comm'r of Internal Revenue

    34 T.C. 73 (U.S.T.C. 1960)   Cited 1 times

    Corliss v. Bowers, 281 U.S. 376. See also Richard R. Deupree, 1 T.C. 113, George W. Drysdale, 32 T.C. 378, on appeal (C.A. 6), and Williams v. United States, 219 F.2d 523 (C.A. 5). As indicated above, we think that there was no limitation or restriction upon the petitioner's right to draw down his current compensation in the years in question.