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literary, or civic achievement". While we have no doubts,
particularly in light of New England winter mornings, that the
Globe's payment was in recognition of Herculean efforts, we
cannot classify those efforts within any of the enumerated
achievements to which section 74(b) is directed. See Hornung v.
Commissioner, 47 T.C. 428, 436-437 (1967). We further note that
under section 74(b)(1), the recipient must have been selected
"without any action on his part to enter the contest or
proceeding". We are not pursuaded that petitioner played no role
in initiating the process that led to the Globe's payment.
Isenbergh v. Commissioner, 31 T.C. 1046, 1051-1053 (1959). In
sum, we must also reject petitioner's section 74(b) argument.
Therefore, respondent's determination is sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011