Legal Opinion

Hall v. Commissioner

United States Tax Court

Decided September 22, 1953No. Docket Nos. 40203, 40204Unpublished

Petitioners, L. C. Hall and C. J. Hall, sometimes in partnership and sometimes individually, operated a so-called numbers business from 1939 to 1951. Each day they collected from their pick-up men players' tickets and the net amounts bet after the deduction of commissions for the services of such pick-up men and writers. Individual players' tickets were retained for one week.

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Petitioners, L. C. Hall and C. J. Hall, sometimes in partnership and sometimes individually, operated a so-called numbers business from 1939 to 1951. Each day they collected from their pick-up men players' tickets and the net amounts bet after the deduction of commissions for the services of such pick-up men and writers. Individual players' tickets were retained for one week. L. C. Hall sent to his accountant a weekly summary of his net intake, amounts paid out in wins, and expenses from which a permanent record was made. Individual tickets were then destroyed. Petitioners' income tax returns…

1Opinion of the Court

Leonard Cephus Hall and Verna G. Hall v. Commissioner. Emma Jane Hall, Surviving Wife of Clayton J. Hall v. Commissioner.

Hall v. Commissioner

Docket Nos. 40203, 40204.

United States Tax Court

1953 Tax Ct. Memo LEXIS 108; 12 T.C.M. (CCH) 1067; T.C.M. (RIA) 53314;

September 22, 1953

Petitioners, L. C. Hall and C. J. Hall, sometimes in partnership and sometimes individually, operated a so-called numbers business from 1939 to 1951. Each day they collected from their pick-up men players' tickets and the net amounts bet after the deduction of commissions for the services of such pick-up men and writers.…

2Cases cited2 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Nahman v. CommissionerUnited States Board of Tax Appeals · 1930

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