Rudolph v. United States
372 U.S. 269 (1962)

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U.S. Supreme Court

Rudolph v. United States, 372 U.S. 269 (1962)

Rudolph v. United States

No. 396

Argued April 3, 1962

Decided June 18, 1962

372 U.S. 269

Syllabus

An insurance company paid the expenses of a group of its agents and their wives, including petitioners, to New York City to attend an annual convention, and the Commissioner assessed the value of the trip to petitioners as taxable income. In a suit for refund, the District Court found that the trip was provided by the company primarily for the purpose of affording a pleasure trip in the nature of a bonus, reward, and compensation for a job well done and that, from the point of view of petitioners, it was primarily a pleasure trip, and that, therefore, the value of the trip was income and the costs were personal and nondeductible. The Court of Appeals approved these findings.

Held: since the ultimate facts are subject to the "clearly erroneous" rule and their review would be of no importance save to the litigants themselves, the writ of certiorari is dismissed as improvidently granted. Pp. 372 U. S. 269-270.

Reported below: 291 F. 2d 841.

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