Reynolds v. Commissioner
United States Tax Court
1. The services rendered by petitioner in the sale of 240 tanks for use of the Chinese Government were only part of his services under his employment contract, and the compensation therefor not being 80 per cent of his total compensation for the services rendered, it is held that the provisions of section 107 (a) of the Internal Revenue Code of 1939 are not applicable. 2. Held, that a bona fide and valid partnership was formed by petitioner and his wife for the conduct of…
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1. The services rendered by petitioner in the sale of 240 tanks for use of the Chinese Government were only part of his services under his employment contract, and the compensation therefor not being 80 per cent of his total compensation for the services rendered, it is held that the provisions of section 107 (a) of the Internal Revenue Code of 1939 are not applicable. 2. Held, that a bona fide and valid partnership was formed by petitioner and his wife for the conduct of business which had formerly been that of petitioner alone, and that the business was thereafter conducted by the…
1Opinion of the Court
George E. Reynolds, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of Mildred D. Reynolds, Deceased, George E. Reynolds, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Reynolds v. Commissioner
Docket Nos. 39399, 39421
United States Tax Court
26 T.C. 1225; 1956 U.S. Tax Ct. LEXIS 77;
September 28, 1956, Filed
Decisions will be entered under Rule 50.
1. The services rendered by petitioner in the sale of 240 tanks for use of the Chinese Government were only part of his services under his employment contract, and the compensation therefor not being 80 per cent…
2Cases cited15 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Strauss v. StraussSupreme Court of Florida · 1941
- Greene v. CommissionerUnited States Tax Court · 1946
- Ohio Butterine Co. v. HargraveSupreme Court of Florida · 1920
- English v. EnglishSupreme Court of Florida · 1913
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