Legal Opinion

Jillson v. Commissioner

United States Tax Court

Decided August 25, 1954No. Docket No. 45371Published

1. Payment received for miscellaneous, unconnected legal services, no one of which exceeded 36-month period held not qualified for reallocation to prior years under section 107 (a), Internal Revenue Code of 1939, notwithstanding that bill was rendered to cover all services performed over period in excess of 36 months. 2. Services performed as attorney by petitioner who was also trustee held severable for purposes of section 107 (a), Internal Revenue Code of 1939, under New…

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1. Payment received for miscellaneous, unconnected legal services, no one of which exceeded 36-month period held not qualified for reallocation to prior years under section 107 (a), Internal Revenue Code of 1939, notwithstanding that bill was rendered to cover all services performed over period in excess of 36 months. 2. Services performed as attorney by petitioner who was also trustee held severable for purposes of section 107 (a), Internal Revenue Code of 1939, under New York law. Rosalyne A. Lesser, 17 T. C. 1479, distinguished. 3. Half of income allocable to previous years under section…

1Opinion of the Court

Leon R. Jillson and Emma K. Jillson, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent

Jillson v. Commissioner

Docket No. 45371

United States Tax Court

22 T.C. 1101; 1954 U.S. Tax Ct. LEXIS 119;

August 25, 1954, Filed August 25, 1954, Filed

Decision will be entered under Rule 50.

1. Payment received for miscellaneous, unconnected legal services, no one of which exceeded 36-month period held not qualified for reallocation to prior years under section 107 (a), Internal Revenue Code of 1939, notwithstanding that bill was rendered to cover all services performed over period…

2Cases cited9 opinions

  1. Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  2. Civiletti v. CommissionerUnited States Tax Court · 1944
  3. Lum v. CommissionerUnited States Tax Court · 1949
  4. Civiletti v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  5. Nast v. CommissionerUnited States Tax Court · 1946

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