Wattley v. Commissioner
United States Tax Court
Petitioner, the owner of all of the stock of a corporation, conducted a real estate brokerage business in its name. In 1951 he received from it a commission which it earned, through services rendered by him as its representative, for negotiating a lease. The commission received did not represent at least 80 per centum of the total compensation for personal services received by petitioner from the corporation during the period covered by the services.
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Petitioner, the owner of all of the stock of a corporation, conducted a real estate brokerage business in its name. In 1951 he received from it a commission which it earned, through services rendered by him as its representative, for negotiating a lease. The commission received did not represent at least 80 per centum of the total compensation for personal services received by petitioner from the corporation during the period covered by the services. Held, the entire commission is taxable income of petitioner for 1951, and section 107 (a) of the Internal Revenue Code of 1939 is not applicable.
1Opinion of the Court
Ralph B. Wattley and Josephine R. Wattley, Petitioners, v. Commissioner of Internal Revenue, Respondent
Wattley v. Commissioner
Docket No. 62297
United States Tax Court
31 T.C. 510; 1958 U.S. Tax Ct. LEXIS 21;
December 11, 1958, Filed
Decision will be entered under Rule 50.
Petitioner, the owner of all of the stock of a corporation, conducted a real estate brokerage business in its name. In 1951 he received from it a commission which it earned, through services rendered by him as its representative, for negotiating a lease. The commission received did not represent at least 80 per centum of the…
2Cases cited10 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Commissioner of Internal Revenue v. Moline Properties, Inc.Court of Appeals for the Fifth Circuit · 1942
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