Legal Opinion
Noel v. Parrott
Court of Appeals for the Fourth Circuit
Decided June 8, 1926No. 2459PublishedCited by 63 opinions
1Opinion of the CourtParker, Circuit Judge
(after stating the facts as above). The sole question involved in this case is whether the $35,000, paid to plaintiff under the circumstances above set forth, is taxable as income under the Revenue Act of 1918. The plaintiff contends that it is not so taxable, his position being that it was a gift, and, as such, expressly exempted from taxation as income under the act. The defendant collector contends that it was not a gift, and, if not treated as “compensation for personal service,” is at least a “gain” or “profit” which under the- statute must be included in the return of gross income.
The…
2Cases cited10 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Hobbs v. McLeanSupreme Court of the United States · 1886
- Merchants' Loan & Trust Co. v. SmietankaSupreme Court of the United States · 1921
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
5 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Silverman v. CommissionerUnited States Tax Court · 1957
- Bass v. HawleyCourt of Appeals for the Fifth Circuit · 1933
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