Legal Opinion

Wakelee v. Commissioner

United States Tax Court

Decided October 31, 1951No. Docket No. 28411Published

Payments made pursuant to agreements between petitioner and a client for trading in securities under which petitioner became entitled to all dividends and 25 per cent of profit from sales, in return for his obligation to pay client an annual return upon sums invested, held deductible as an expense for the production or collection of income under section 23 (a) (2), Internal Revenue Code.

1Opinion of the Court

Louis E. Wakelee and Lillie E. Wakelee, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent

Wakelee v. Commissioner

Docket No. 28411

United States Tax Court

17 T.C. 745; 1951 U.S. Tax Ct. LEXIS 49;

October 31, 1951, Promulgated

Decision will be entered under Rule 50.

Payments made pursuant to agreements between petitioner and a client for trading in securities under which petitioner became entitled to all dividends and 25 per cent of profit from sales, in return for his obligation to pay client an annual return upon sums invested, held deductible as an expense for the…

2Cases cited7 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Wiesler v. CommissionerUnited States Tax Court · 1946
  3. 58th Street Plaza Threatre, Inc. v. CommissionerUnited States Tax Court · 1951
  4. Commissioner v. WieslerCourt of Appeals for the Sixth Circuit · 1947
  5. Hess v. CommissionerUnited States Tax Court · 1946

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