Stanton v. United States
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| Stanton v. United States | |
|---|---|
 | |
| Court | United States Court of Appeals for the Second Circuit |
| Full case name | Alden D. Stanton and Louise M. Stanton v. United States of America |
| Argued | May 14, 1959 |
| Decided | July 6, 1959 |
| Citation | 268 F.2d 727 (2d Cir. 1959) |
| Case history | |
| Subsequent history | On remand, 186 F. Supp. 393 (E.D.N.Y. 1960) |
| Court membership | |
| Judges sitting | Learned Hand, Thomas Walter Swan, Carroll C. Hincks |
| Case opinions | |
| Majority | Hand, joined by Swan |
| Dissent | Hincks |
| Laws applied | |
| Internal Revenue Code | |
Stanton v. United States, 268 F.2d 727 (2d Cir. 1959),[1] was a United States income tax case in the United States Court of Appeals for the Second Circuit.
Facts
Plaintiff husband managed the property of the Trinity Church (Manhattan) until a corporation was formed which took over that work. Plaintiff husband then became that corporation's president, and all of his time was spent caring for the corporation's real estate. When plaintiff husband resigned, the corporation gave him a gratuity in appreciation of his services. He was provided $20,000. He had to waive all his retirement and pension benefits.
Tax returns
Plaintiffs admitted that gratuity on their income tax returns, but did not include it as income because it was a gift.
The tax commissioner decided that it was income and assessed a tax deficiency, which plaintiffs paid, and thereafter filed a claim for a refund. Defendant denied that claim.
Tax court
The trial court held in plaintiffs' favor.