Ford v. Commissioner
United States Tax Court
Section 107 (a) -- Computation of Taxes Attributable to Prior Years. -- Long term compensation for legal services of husband received in 1945 allocable to years 1937-1945 under section 107 (a). The compensation and all other income for all years involved is community income, one-half of which is the income of each spouse for income tax purposes. Separate returns were filed by each petitioner for 1937 and 1945; a single joint return was filed for the other years.
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Section 107 (a) -- Computation of Taxes Attributable to Prior Years. -- Long term compensation for legal services of husband received in 1945 allocable to years 1937-1945 under section 107 (a). The compensation and all other income for all years involved is community income, one-half of which is the income of each spouse for income tax purposes. Separate returns were filed by each petitioner for 1937 and 1945; a single joint return was filed for the other years. Each petitioner seeks to compute tax attributable to "allocated" compensation for years prior to 1945 -- i. e., 1943 and 1944 -- on…
1Opinion of the Court
George K. Ford, et al., Petitioners, v. Commissioner of Internal Revenue, Respondent
Ford v. Commissioner
Docket Nos. 28481, 284821
United States Tax Court
18 T.C. 387; 1952 U.S. Tax Ct. LEXIS 183;
May 23, 1952, Promulgated
Decision will be entered for the respondent.
Section 107 (a) -- Computation of Taxes Attributable to Prior Years. -- Long term compensation for legal services of husband received in 1945 allocable to years 1937-1945 under section 107 (a). The compensation and all other income for all years involved is community income, one-half of which is the income of each spouse for income tax…
2Cases cited14 opinions
- United States v. MalcolmSupreme Court of the United States · 1931
- Ferguson v. CommissionerUnited States Tax Court · 1950
- Taft v. HelveringSupreme Court of the United States · 1940
- Helvering v. JanneySupreme Court of the United States · 1940
- Sutor v. CommissionerUnited States Tax Court · 1951
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