Oppenheim v. Commissioner
United States Board of Tax Appeals
Sums received by author, the owner of copyrights, under contracts granting privilege, exclusive within specified territory, of publishing and selling his books, held, not compensation for personal services rendered.
1Opinion of the Court
opinion.
Goodrich:
Respondent determined deficiencies in income tax of $334.99 for 1928 and $386.85 for 1929. He demands also penalties for delinquent returns amounting to 25 percent of the deficiencies in each of these years, or $83.75 and $96.59, respectively. Petitioner assails the determination of deficiencies as erroneous, but offers no defense against the imposition of the penalties. There is but one issue for our decision in the case, namely, whether sums received by petitioner in accordance with contracts in each of these years are to be treated as earned income in computing credit…
2Cited by5 opinions
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- Oppenheim v. CommissionerUnited States Board of Tax Appeals · 1934
- Tobey v. Comm'rUnited States Tax Court · 1973