## Facts

- Margaret Cramer Green regularly sold blood plasma to a laboratory in Pensacola, Florida, using a plasmapheresis process in which plasma was separated and red blood cells returned to her body.
- Green had a rare blood type, making her plasma valuable to purchasers who processed and marketed it.
- In 1976, Green made 95 plasma sales and was paid by the pint; she also received a $5 travel allowance per visit (totaling $475).
- Green’s plasma activity was her primary source of funds; she also earned wages from other employers during 1976.
- On her 1976 return, Green reported plasma receipts as income and claimed extensive deductions attributed to the plasma activity, including medical insurance premiums, special drugs, high-protein foods, transportation, and a claimed depletion allowance for “minerals and antibodies” in her blood.
- The Commissioner disallowed many claimed deductions and determined a 1976 income-tax deficiency of $577; Green petitioned the Tax Court.

## Issues

1. Whether payments received for plasma “donations” were income from a trade or business.
2. Whether claimed costs (including health insurance, drugs, special diet foods, and transportation) were deductible as ordinary and necessary business expenses under I.R.C. § 162 or were nondeductible personal/medical expenses (deductible, if at all, under I.R.C. § 213).
3. Whether a depletion deduction under I.R.C. § 611 was available for alleged depletion of “minerals and antibodies” from Green’s blood.

## Decision

- The court held that Green’s plasma receipts were ordinary income from her trade or business of selling blood plasma.
- The court held that health insurance was an inherently personal expense, deductible only as allowed under the medical-expense rules of I.R.C. § 213, not as a § 162 business expense.
- The court rejected the claimed depletion allowance, holding that bodily losses from plasma sales are not depletion of “natural deposits” within I.R.C. § 611.
- The court allowed only limited business deductions to the extent specific expenses were shown to be directly connected to carrying on the plasma-selling business, and sustained the deficiency in part.

## Legal Principles

- Regular, profit-motivated sales of blood plasma can constitute a trade or business, making receipts taxable as ordinary income and placing related deductions within the § 162 framework.
- Expenses that are inherently personal or medical (including health insurance and general health-maintenance costs) are not deductible under § 162; they are deductible, if at all, only under the medical-expense provisions of § 213.
- Transportation resembling commuting between home and a regular place of activity is generally personal and nondeductible; only amounts sufficiently connected to business activity may qualify under § 162.
- I.R.C. § 611 depletion applies to “natural deposits” in the statutory sense and does not extend to the human body or alleged depletion of blood constituents.

## Conclusion

The Tax Court treated Green’s paid plasma “donations” as business income but limited deductions to those directly tied to the plasma-selling activity, reclassified health-related outlays as personal/medical items governed by § 213, and denied any depletion deduction because human blood is not a “natural deposit” under § 611.


Green v. Commissioner, 74 T.C. 1229 (1980)