Legal Opinion
Commissioner of Internal Revenue v. Franklin A. Reece
Court of Appeals for the First Circuit
Decided May 3, 1956No. 5091PublishedCited by 27 opinions
1Opinion of the Court
MAGRUDER, Chief Judge.
The Commissioner asks us to review a decision of the Tax Court entered August 10, 1955, concluding that there is no deficiency in the income tax of Franklin A. Reece for the calendar year 1947. In determining a deficiency, the Commissioner had ruled that certain “royalty” income paid to the taxpayer’s wife pursuant to an assignment must be attributed to the taxpayer and included in his gross income for the year 1947. The Tax Court held otherwise. We think the Tax Court was right.
There are no facts in dispute. In 1928 the taxpayer invented a “helical traverse double…
2Cases cited13 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
8 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Wood Harmon Corporation v. United StatesCourt of Appeals for the Second Circuit · 1963
- Miedaner v. CommissionerUnited States Tax Court · 1983
- Thomas L. Fawick and Marie Fawick v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1971
- Horne v. PeckhamCalifornia Court of Appeal · 1979
- Fawick v. Comm'rUnited States Tax Court · 1969
22 more not listed; retrieve them via the Exa API.