Zeltzerman v. Commissioner
United States Tax Court
Petitioner during the years 1954, 1955, and 1956 rendered services as a radiologist to two exempt hospitals described in section 501 (c)(3), I.R.C. 1954, under oral contracts pursuant to which his compensation was measured by a percentage of the charges made by the hospitals for X-ray services.
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Petitioner during the years 1954, 1955, and 1956 rendered services as a radiologist to two exempt hospitals described in section 501 (c)(3), I.R.C. 1954, under oral contracts pursuant to which his compensation was measured by a percentage of the charges made by the hospitals for X-ray services. In mid-1954, pursuant to a proposal of the petitioner, the hospitals ceased to pay the petitioner his monthly compensation in cash but used it to purchase annuities for him at each yearend. Held, that there was no binding agreement between him and the hospitals which restricted the petitioner's right…
1Opinion of the Court
AtkiNS, Judge:
Respondent determined deficiencies in income tax of petitioners for the years 1954, 1955, and 1956 in the respective amounts of $2,688.70, $4,583.80, and $5,455.05.
The only issue presented is whether there should be included in the income of the petitioner Morris Zeltzerman the amounts used by the Morrison and the Lancaster Hospitals in acquiring annuity contracts for the petitioner or on account of the receipt by the petitioner of rights in such annuities.
FINDINGS OF FACT.
Some of the facts were stipulated, the stipulations being incorporated herein by this reference.
The…
2Cases cited9 opinions
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Deupree v. CommissionerUnited States Tax Court · 1942
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
- Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
- Taylor v. CommissionerUnited States Tax Court · 1943
4 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Cohen v. CommissionerUnited States Tax Court · 1974
- Goldsmith v. United StatesUnited States Court of Claims · 1978
- Maxwell B. Llewellyn and Gertrude Llewellyn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Nicholson v. CommissionerUnited States Tax Court · 1993
- Arizona State Tax Commission v. ReiserArizona Supreme Court · 1973
5 more not listed; retrieve them via the Exa API.