Legal Opinion
Levey v. Helvering
Court of Appeals for the D.C. Circuit
Decided December 4, 1933No. 5891PublishedCited by 21 opinions
1Opinion of the Court
GRONER, Associate Justice.
The single question presented on this peti- ■ tion is whether a certain sum of money received by petitioner from his employer, the Frederick H. Levey Company, Inc., during the year 1928, was “compensation” or a “gift.” The Commissioner held it was compensation for services rendered and was taxable. Sections 212 and 213, Revenue Act 1926, 44 Stat. 23 (26 USCA §§ 953, 954); Revenue Act 1928, §§ 212, 213> 45 Stat. 791 (26 USCA §§ 2212, 2213). The Board sustained the Commissioner.
The Levey Company was a New York corporation'. Petitioner was for many years its…
2Cases cited5 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Nielsen v. JohnsonSupreme Court of the United States · 1929
- Noel v. ParrottCourt of Appeals for the Fourth Circuit · 1926
- Lincoln Nat. Bank v. BurnetCourt of Appeals for the D.C. Circuit · 1933
- Payne v. United States ex rel. MosierCourt of Appeals for the D.C. Circuit · 1921
3Cited by21 opinions
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Flood v. United StatesCourt of Appeals for the First Circuit · 1943
- Poorman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Botchford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1936
- Bergan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
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