Legal Opinion
Ralph B. Wattley and Josephine R. Wattley v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 16, 1960No. 104, Docket 25801PublishedCited by 5 opinions
1Opinion of the Court
MAGRUDER, Circuit Judge.
Nobody enjoys paying taxes. This, is particularly true of a taxpayer who receives a large commission in a given year as the culmination of years of service and who is told to report the income as all having been received in that year, thus boosting him into the higher tax brackets.
To some extent the Congress was sympathetic to the above feeling, so that in enacting the Internal Revenue Code of 1939 it provided in § 107(a) as follows:
Ҥ 107. Compensation for services rendered for a period of thirty-six months or more and back pay.
“(a) Personal services. If at least 80…
2Cases cited10 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Sussdorff v. . SchmidtNew York Court of Appeals · 1873
- Lloyd v. . MatthewsNew York Court of Appeals · 1872
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
5 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Maurice J. Breen and Alyce J. Breen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Julien J. Studley, Inc. v. Gulf Oil CorporationCourt of Appeals for the Second Circuit · 1967
- Burr v. CommissionerUnited States Tax Court · 1966
- Ralph B. Wattley and Josephine R. Wattley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Wattley v. CommissionerUnited States Tax Court · 1961