Sanders v. Commissioner
United States Tax Court
1. Taxability of Income -- Settlement Did Not Include Settlement of Taxes. -- The settlement of the petitioner's claims for additional compensation arising from a contract to perform work for the United States Government did not include the settlement of the petitioner's income tax liability. 2. Capital Gain or Ordinary Income -- Contract Settlement. -- The amounts paid in a settlement of the petitioner's claims for additional compensation arising from a contract to perform…
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1. Taxability of Income -- Settlement Did Not Include Settlement of Taxes. -- The settlement of the petitioner's claims for additional compensation arising from a contract to perform work for the United States Government did not include the settlement of the petitioner's income tax liability. 2. Capital Gain or Ordinary Income -- Contract Settlement. -- The amounts paid in a settlement of the petitioner's claims for additional compensation arising from a contract to perform work were ordinary income to the petitioner and not capital gain. 3. Deductions -- Depreciation -- Separately Owned…
1Opinion of the Court
OPINION.
Murdock, Judge:
The following allegation in the petition filed February 3,1953, is the basis of the petitioners’ first contention:
One of the matters between the petitioner and the government arising by reason of or in connection with Contract No. W-957-eng-968 was the taxability of amounts accrued or paid to petitioner under the contract and in settlement of claims in the year 1949, which was settled in one of a series of acts or steps in one entire transaction, as aforesaid.
Leo and his administrative assistant testified, in effect, that Gaines V. Palmes, the Justice Department…
2Cases cited16 opinions
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- Hale v. HelveringCourt of Appeals for the D.C. Circuit · 1936
- West Side Tennis Club v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Downs v. CommissionerUnited States Tax Court · 1946
- Safety Tube Corp. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
11 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Sally Conforte v. Commissioner of Internal Revenue, Joseph Conforte v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Jones v. CommissionerUnited States Tax Court · 1956
- Conforte v. CommissionerUnited States Tax Court · 1980
- Bagur v. Comm'rUnited States Tax Court · 1976
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
54 more not listed; retrieve them via the Exa API.