Morrison v. Commissioner

OPINION.

Ofper, Judge:

The related proceeding of James D. Moore, Docket No. 17007, decided March 18,1949, by memorandum opinion, deals with services rendered by and compensation paid to a receiver. The present petitioners functioned as receivers’ counsel in the same receivership. The related case concluded on the authority of Ralph E. Lum, 12 T. C. 375, that of the total payment for services, not apparently divisible, the amount received in the current year was less than 80 per cent, and that section 107 was consequently inapplicable.

"We are compelled to the same conclusion here. We do not mean…