Kyle v. Commissioner
United States Board of Tax Appeals
1. The petitioners, attorneys at law, making their returns on the cash receipts basis, performed numerous separate legal services for a dealer in coal properties, such services extending over a period from 1909 to 1915, when their client's affairs were placed in the hands of receivers. In the latter year the petitioners acquired a judgment for the value of their services and interest.
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1. The petitioners, attorneys at law, making their returns on the cash receipts basis, performed numerous separate legal services for a dealer in coal properties, such services extending over a period from 1909 to 1915, when their client's affairs were placed in the hands of receivers. In the latter year the petitioners acquired a judgment for the value of their services and interest. The judgment, plus interest to date of payment, was paid in cash in 1920 and the Commissioner determined that the entire amount received in cash was income to the petitioners for that year. Held, that the…
1Opinion of the Court
WILLIAM J. KYLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PATRICK D. REINHART, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Kyle v. Commissioner
Docket Nos. 16701, 16702.
United States Board of Tax Appeals
15 B.T.A. 1247; 1929 BTA LEXIS 2695;
April 4, 1929, Promulgated
1. The petitioners, attorneys at law, making their returns on the cash receipts basis, performed numerous separate legal services for a dealer in coal properties, such services extending over a period from 1909 to 1915, when their client's affairs were placed in the hands of receivers. In the latter…
2Cases cited1 opinion
- Kyle v. CommissionerUnited States Board of Tax Appeals · 1929