GREENAWALT v. COMMISSIONER
United States Board of Tax Appeals
The petitioner is not entitled to the maximum earned income credit provided for in section 31(a) of the Revenue Act of 1928 in respect of royalties, computed upon a per ton basis, received under certain contracts with licensees embodying the use of patents relating to the process of sintering.
1Opinion of the Court
*939OPINION.
Smith :
The petitioner contends that he is entitled in the computation of his tax liability for 1928 to the maximum earned income credit of $30,000, as provided in section 31 of the Eevenue Act of 1928. This section of the act reads in part as follows:
Siso. 31. Earned income credit.(a) Definitions. — Eor the purposes of this section—(1) “Earned income” means wages, salaries, professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by…
2Cases cited2 opinions
- De Laski & Thropp Circular Woven Tire Co. v. IredellDistrict Court, D. New Jersey · 1920
- Iredell v. De Laski & Thropp Circular Woven Tire Co.Court of Appeals for the Third Circuit · 1923
3Cited by6 opinions
- Tobey v. Comm'rUnited States Tax Court · 1973
- GREENAWALT v. COMMISSIONERUnited States Board of Tax Appeals · 1933
- Harroun v. CommissionerUnited States Tax Court · 1945
- Norton v. CommissionerUnited States Tax Court · 1962
- Oppenheim v. CommissionerUnited States Board of Tax Appeals · 1934
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