Wattley v. Commissioner

OPINION.

Raum, Judge:

The principal issue relates to the commission of $30,666.67 paid by Mutual to R. B. Wattley Co. Inc. in 1951, and distributed by the latter to petitioner during the same year. The petitioner contends that R. B. Wattley Co. Inc. was merely a “dummy” or “front” used by him in carrying on his business as a real estate broker; that the $30,666.67 was a commission received by him for services which he rendered over a period of 19 years and 9 months as an individual and not as a representative of his wholly owned corporation; and that under the provisions of section 107 (a) of…