Schumacher v. United States

WILLIAMS, Judge.

The plaintiff in this case seeks to recover $25,000, with interest thereon, an alleged overpayment of his income taxes for the calendar year 1925., The sole issue in the ease is whether an amount of $100,000 received by the plaintiff from the stockholder’s committee of the El Paso & Southwestern Company in January, 1925, was income derived from compensation for personal services within the meaning of section 213 (a) of the Revenue Act of 1924 (26- USCA § 954 (a), or was a gift within the meaning of section 213 (b) (3) of said act (26 USCA.§ 954 (b) (3) and note).

The rule is…