Legal Opinion

Field v. Commissioner

United States Board of Tax Appeals

Decided March 6, 1929No. Docket No. 11840Published

1. Held that certain income from a trust fund received by the petitioner's wife pursuant to a formal and complete assignment by him to her of his interest therein should not be included in the petitioner's taxable income. 2. Where attorney's fees paid in installments pursuant to a contingent-fee contract for services which resulted in a decree for the petitioner under which income which otherwise he could not have received was paid to him, it is held, under the peculiar…

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1. Held that certain income from a trust fund received by the petitioner's wife pursuant to a formal and complete assignment by him to her of his interest therein should not be included in the petitioner's taxable income. 2. Where attorney's fees paid in installments pursuant to a contingent-fee contract for services which resulted in a decree for the petitioner under which income which otherwise he could not have received was paid to him, it is held, under the peculiar circumstances of this case, that the payments should be deducted in computing net income for the year in which such payments…

1Opinion of the Court

MARSHALL FIELD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Field v. Commissioner

Docket No. 11840.

United States Board of Tax Appeals

15 B.T.A. 718; 1929 BTA LEXIS 2802;

March 6, 1929, Promulgated

1. Held that certain income from a trust fund received by the petitioner's wife pursuant to a formal and complete assignment by him to her of his interest therein should not be included in the petitioner's taxable income.

2. Where attorney's fees paid in installments pursuant to a contingent-fee contract for services which resulted in a decree for the petitioner under which income which…

2Cases cited8 opinions

  1. Mitchel v. CommissionerUnited States Board of Tax Appeals · 1924
  2. Le Blanc v. CommissionerUnited States Board of Tax Appeals · 1927
  3. Field v. CommissionerUnited States Board of Tax Appeals · 1929
  4. Rosenwald v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Van Brunt v. CommissionerUnited States Board of Tax Appeals · 1928

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