Shaffer v. Commissioner
United States Tax Court
Held, that in determining whether or not at least 80 per cent of the total compensation for personal services of petitioner, as trustee under a single appointment in a reorganization proceeding, in which his services and compensation therefor covered a period of more than 36 calendar months, was received in one taxable year, all compensation received by petitioner as trustee must be taken into consideration, although the allowance of compensation to him was by separate…
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Held, that in determining whether or not at least 80 per cent of the total compensation for personal services of petitioner, as trustee under a single appointment in a reorganization proceeding, in which his services and compensation therefor covered a period of more than 36 calendar months, was received in one taxable year, all compensation received by petitioner as trustee must be taken into consideration, although the allowance of compensation to him was by separate provisions of an order of court for services rendered in relation to differing aspects of his activities as trustee in…
1Opinion of the Court
R. O. Shaffer and Mildred M. Shaffer, Petitioners, v. Commissioner of Internal Revenue, Respondent
Shaffer v. Commissioner
Docket No. 53993
United States Tax Court
29 T.C. 187; 1957 U.S. Tax Ct. LEXIS 48;
November 7, 1957, Filed
Decision will be entered under Rule 50.
Held, that in determining whether or not at least 80 per cent of the total compensation for personal services of petitioner, as trustee under a single appointment in a reorganization proceeding, in which his services and compensation therefor covered a period of more than 36 calendar months, was received in one taxable year, all…
2Cases cited15 opinions
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Civiletti v. CommissionerUnited States Tax Court · 1944
- Lum v. CommissionerUnited States Tax Court · 1949
- Civiletti v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Cowan v. Henslee, Collector of Internal Revenue. Klein v. Henslee, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
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