Legal Opinion

Dixon v. Commissioner

United States Tax Court

Decided May 14, 1951No. Docket Nos. 22165, 22166, 22167, 22168Published

1. Section 107 (a) -- Compensation for Personal Services -- Building and Selling Houses. -- Section 107 (a) does not apply to the distributive shares of partnership income of partners who contributed only services to the partnership engaged in subdividing land and building thereon and selling low cost houses. 2. Section 44 (d) -- Transmission or Disposition. -- Section 44 (d) applies where a partnership, reporting sales of real estate on the installment method, transferred…

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1. Section 107 (a) -- Compensation for Personal Services -- Building and Selling Houses. -- Section 107 (a) does not apply to the distributive shares of partnership income of partners who contributed only services to the partnership engaged in subdividing land and building thereon and selling low cost houses. 2. Section 44 (d) -- Transmission or Disposition. -- Section 44 (d) applies where a partnership, reporting sales of real estate on the installment method, transferred its installment obligations to a trust created by the partners who then terminated the partnership.

1Opinion of the Court

Doyle J. Dixon, Petitioner, v. Commissioner of Internal Revenue, Respondent. Flavia R. Dixon, Petitioner, v. Commissioner of Internal Revenue, Respondent. Richard O. Atkinson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Lee Lane Atkinson, Petitioner, v. Commissioner of Internal Revenue, Respondent

Dixon v. Commissioner

Docket Nos. 22165, 22166, 22167, 22168

United States Tax Court

16 T.C. 1016; 1951 U.S. Tax Ct. LEXIS 197;

May 14, 1951, Promulgated

Decisions will be entered for the respondent.

1. Section 107 (a) -- Compensation for Personal Services -- Building and Selling Houses.…

2Cases cited4 opinions

  1. Rogers v. CommissionerUnited States Tax Court · 1943
  2. Waddell v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fifth Circuit · 1939
  3. Goldberg v. CommissionerUnited States Tax Court · 1950
  4. Dixon v. CommissionerUnited States Tax Court · 1951

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