Ford v. Commissioner
United States Tax Court
Section 107 (a) -- Computation of Taxes Attributable to Prior Years. -- Long term compensation for legal services of husband received in 1945 allocable to years 1937-1945 under section 107 (a). The compensation and all other income for all years involved is community income, one-half of which is the income of each spouse for income tax purposes. Separate returns were filed by each petitioner for 1937 and 1945; a single joint return was filed for the other years.
Read the full summary
Section 107 (a) -- Computation of Taxes Attributable to Prior Years. -- Long term compensation for legal services of husband received in 1945 allocable to years 1937-1945 under section 107 (a). The compensation and all other income for all years involved is community income, one-half of which is the income of each spouse for income tax purposes. Separate returns were filed by each petitioner for 1937 and 1945; a single joint return was filed for the other years. Each petitioner seeks to compute tax attributable to "allocated" compensation for years prior to 1945 -- i. e., 1943 and 1944 -- on…
1Opinion of the Court
OPINION.
HaRRon, Judge:
The petitioners, husband and wife, filed separate, individual income tax returns for 1945. All of their income for 1945 is community income, and each spouse reported his one-half thereof in his separate, individual return. The respondent has determined a deficiency for each petitioner, part of which is in dispute. The question to be decided arises under section 107 (a) of the Code2 and is whether the respondent has computed correctly under section 107 (a) the aggregate of the taxes attributable to the parts of long term compensation “allocable” to prior years. He has…
2Cases cited13 opinions
- United States v. MalcolmSupreme Court of the United States · 1931
- Ferguson v. CommissionerUnited States Tax Court · 1950
- Taft v. HelveringSupreme Court of the United States · 1940
- Helvering v. JanneySupreme Court of the United States · 1940
- Sutor v. CommissionerUnited States Tax Court · 1951
8 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Stockly v. CommissionerUnited States Tax Court · 1954
- George K. Ford and Helen L. Ford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- Redpath v. CommissionerUnited States Tax Court · 1952
- Theodore Koppelman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Ford v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.