Keeble v. Commissioner
United States Tax Court
Petitioners on June 4, 1940, received compensation for personal services rendered covering a period of 61 months and 18 days commencing on April 17, 1935. The compensation was payable only on completion of such services. Held that petitioners correctly computed their income tax in accordance with the provisions of section 107, I. R. C., added by section 220 of the Revenue Act of 1939.
1Opinion of the Court
OPINION.
Mellott, Judge'.
These consolidated proceedings involve the following deficiencies in income tax for the calendar year 1940: John Bell Keeble, Jr., Docket No. 112186, $3,644.19; and David M. Keeble, Docket No. 112249, $497.78.
The sole issue is, Are petitioners entitled to have a fee for legal services, received in 1940, taxed under the provisions of section 107 of the Internal Revenue Code? The section, as originally enacted and as applicable here, is shown in the margin.1
The facts are found to be as stipulated. Summarizing them, petitioners, members of a Nashville, Tennessee, law…
2Cases cited17 opinions
- Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
- Knowlton v. MooreSupreme Court of the United States · 1900
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- United States v. Missouri Pacific RailroadSupreme Court of the United States · 1929
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
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3Cited by34 opinions
- Anderson v. CommissionerUnited States Tax Court · 1976
- Estate of Nicol v. CommissionerUnited States Tax Court · 1971
- Graves v. CommissionerUnited States Tax Court · 1987
- Smith v. CommissionerUnited States Tax Court · 1944
- Caltex Oil Venture v. Comm'rUnited States Tax Court · 2012
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