Warren v. Commissioner
United States Tax Court
From January 12, 1939, to and including June 14, 1947, petitioner W. Harold Warren was a substituted trustee for trusts created under the will of T. Frank Appleby, deceased. In such capacity he received commissions for collecting the income of the trusts and also commissions based on the corpus of the trusts.
Read the full summary
From January 12, 1939, to and including June 14, 1947, petitioner W. Harold Warren was a substituted trustee for trusts created under the will of T. Frank Appleby, deceased. In such capacity he received commissions for collecting the income of the trusts and also commissions based on the corpus of the trusts. In determining whether petitioner is entitled to the relief provided for in section 107, Internal Revenue Code, as amended, for the taxable year 1947, held, the "total compensation for personal services" as those words are used in the Code include both the commissions for collecting…
1Opinion of the Court
W. Harold Warren and Lilia L. Warren, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Warren v. Commissioner
Docket No. 40393
United States Tax Court
20 T.C. 378; 1953 U.S. Tax Ct. LEXIS 157;
May 19, 1953, Promulgated
Decision will be entered for the respondent.
From January 12, 1939, to and including June 14, 1947, petitioner W. Harold Warren was a substituted trustee for trusts created under the will of T. Frank Appleby, deceased. In such capacity he received commissions for collecting the income of the trusts and also commissions based on the corpus of the trusts.…
2Cases cited7 opinions
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Lum v. CommissionerUnited States Tax Court · 1949
- Spears v. CommissionerUnited States Tax Court · 1946
- Spears v. CommissionerCourt of Appeals for the Third Circuit · 1947
- Warren v. CommissionerUnited States Tax Court · 1953
2 more not listed; retrieve them via the Exa API.