Groth v. Commissioner
United States Board of Tax Appeals
EARNED INCOME. - Income received in compromise of a claim for liquidated damages or penalty upon the cancellation of a contract is not "earned income" within the meaning of section 31(a)(1) of the Revenue Act of 1928.
1Opinion of the Court
OPINION.
Leech:
The respondent determined a deficiency in income tax against petitioner in the sum of $337.50 for the calendar year 1931. The only error assigned is the action of the Commissioner in refusing to classify as earned income of the' petitioner, the sum of $22,000 received by him in the taxable year from Kresge Department Stores, Inc. The facts were stipulated.
On April 30, 1927, the petitioner entered into a contract with Kresge Department Stores Corporation covering his services as senior vice president and general manager for a period of five years' *797commencing June 1, 1927, and…
2Cases cited6 opinions
- Sun Printing and Publishing Assn. v. MooreSupreme Court of the United States · 1902
- Mosler Safe Co. v. Maiden Lane Safe Deposit Co.New York Court of Appeals · 1910
- Watson v. . RussellNew York Court of Appeals · 1896
- Derry v. Board of EducationMichigan Supreme Court · 1894
- Warth v. . LiebovitzNew York Court of Appeals · 1904
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Groth v. CommissionerUnited States Board of Tax Appeals · 1935