Bradley v. Commissioner
United States Tax Court
Petitioner, in April 1957, accepted employment with the E. R. Carpenter Co., Inc., and assumed his duties in Richmond, Va., on May 1, 1957. He had previously been employed by the duPont Company in Wilmington, Del. Petitioner owned real property in Wilmington consisting of his personal residence and a garage apartment rented to other persons.
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Petitioner, in April 1957, accepted employment with the E. R. Carpenter Co., Inc., and assumed his duties in Richmond, Va., on May 1, 1957. He had previously been employed by the duPont Company in Wilmington, Del. Petitioner owned real property in Wilmington consisting of his personal residence and a garage apartment rented to other persons. When petitioner accepted employment with E. R. Carpenter Co., he intended to sell the Wilmington property and move his family to Richmond. His family was to remain in Wilmington until the residence was sold. Petitioner did not anticipate difficulty in…
1Opinion of the Court
Fisher, Judge:
Respondent determined a deficiency in income tax against petitioners in the amount of $1,955.56 for the year 1958.
The issue presented is whether payment by petitioner’s employer to petitioner in the amount of $5,000 in 1958, pursuant to employer’s voluntary guarantee against loss by petitioner on the sale of his property, was incentive compensation or part of the proceeds of the sale of said property.
BINDINGS OE FACT.
Some of the facts are stipulated and are included herein by reference.
Petitioners, Harris W. Bradley and Patricia G. Bradley, are husband and wife. They filed a…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Kobacker v. CommissionerUnited States Tax Court · 1962
3Cited by20 opinions
- James J. Ritter v. The United StatesUnited States Court of Claims · 1968
- Ferebee v. CommissionerUnited States Tax Court · 1963
- Lull v. CommissionerUnited States Tax Court · 1969
- Pederson v. CommissionerUnited States Tax Court · 1966
- Keener v. CommissionerUnited States Tax Court · 1972
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