Dixon v. Commissioner

OPINION.

Murdock, Judge:

The petitioners first contention is that section 107 (a) applies. They cite no cases in point. Section 107 (a) provides:

If at least 80 per centum of the total compensation for personal services covering a period of thirty-six calendar months or more (from the beginning to the completion of such services) is received or accrued in one taxable year by an individual or a partnership, the tax attributable to any part thereof which is included in the gross income of any individual shall not be greater than the aggregate of the taxes attributable to such part had it been…