Marshall v. Commissioner
United States Tax Court
Partnership income received by petitioner as his share of compensation for services rendered by the partnership over a period exceeding 36 months, held subject to allocation over the entire period, under section 107 (a), Internal Revenue Code, notwithstanding part of the services were rendered before petitioner's admission to partnership.
1Opinion of the Court
OPINION.
Opper, Judge-.
The deficiencies in issue are for income tax in the respective amounts of $5,388.96 for the year 1943 in Docket No. 23432 and $3,001.64 for the year 1945 in Docket No. 23433. Petitioner. claims an overpayment. The issue in each of the consolidated proceedings is whether petitioner, as a member of a law partnership, is entitled to apply section 107, Internal Revenue Code, so as to include in the time of the rendition of the services the period prior to his admission to the partnership.
The facts have been stipulated and are hereby found accordingly. Elder W. Marshall,…
2Cases cited4 opinions
- Keeble v. CommissionerUnited States Tax Court · 1943
- Stallforth v. CommissionerUnited States Tax Court · 1946
- Knox v. CommissionerUnited States Tax Court · 1948
- Lindstrom v. CommissionerUnited States Tax Court · 1944
3Cited by12 opinions
- Hofferbert v. Marshall Et UxCourt of Appeals for the Fourth Circuit · 1952
- Sovik v. ShaughnessyDistrict Court, N.D. New York · 1950
- Commissioner of Internal Revenue v. Elder W. Marshall, Commissioner of Internal Revenue v. Elder W. Marshall and Bessie I. MarshallCourt of Appeals for the Third Circuit · 1950
- Marshall v. HofferbertDistrict Court, D. Maryland · 1952
- John E. McClure and Helen M. McClure v. The United States of AmericaCourt of Appeals for the Fourth Circuit · 1955
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