Legal Opinion
Travis T. Wallace, Hazel J. Wallace, C. O. Hambleton and Sallie B. Hambleton v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 2, 1955No. 15053PublishedCited by 14 opinions
1Opinion of the Court
TUTTLE, Circuit Judge.
The sole issue on this petition for review is whether certain payments made to Messrs. Wallace and Hambleton in 1946, 1947 and 1948 by their employer, the Great American Reserve Insurance Company, were gifts or compensation for services rendered. The Tax Court held that they were compensation and therefore taxable income under 26 U.S.C.A. § 22(a).
The material facts were stipulated, and those facts are fully stated in the Tax Court memorandum decision, 12 T.C.M. 1462. A brief résumé is sufficient here. Taxpayers Wallace and Hambleton filed community property returns or…
2Cases cited26 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- United States v. MerriamSupreme Court of the United States · 1923
- Carragan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- WD Haden Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
21 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Ethel West Cotnam v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Silverman v. CommissionerUnited States Tax Court · 1957
- Hilda Bounds v. United StatesCourt of Appeals for the Fourth Circuit · 1958
- Walker v. CommissionerUnited States Tax Court · 1956
- Fisher v. United StatesDistrict Court, D. Massachusetts · 1955
9 more not listed; retrieve them via the Exa API.