Blake v. Commissioner
United States Tax Court
1. Gross Income -- Compensation for Services Other Than Cash -- Year Taxable. -- A client conveyed an interest in real property in 1937 to an attorney for services rendered and for services to be rendered; a cloud on the title to the property was removed in 1944. Held, the reasonable value of the property not includible in gross income in 1944. 2. Separate Income from Separate Property -- Community Property -- Year Taxable. -- Held, under state law payment received from the…
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1. Gross Income -- Compensation for Services Other Than Cash -- Year Taxable. -- A client conveyed an interest in real property in 1937 to an attorney for services rendered and for services to be rendered; a cloud on the title to the property was removed in 1944. Held, the reasonable value of the property not includible in gross income in 1944. 2. Separate Income from Separate Property -- Community Property -- Year Taxable. -- Held, under state law payment received from the sale of oil and gas from the separate property of petitioner was his separate income; held, further, that for the…
1Opinion of the Court
OPINION.
Issue 1.
Johnson, Judge:
The first issue is, when did petitioner receive compensation for legal services performed and to be performed? Was it in 1937 or in 1944? The compensation in question is the reasonable value of an undivided one-fourth of a one-half interest in a 76-acre tract. Petitioner contends that he received his compensation in 1937. He maintains that he received title to his interest in this property when the 1937 agreement was executed and delivered by Clara May Downey, or, in the alternative, in 1943, when the “Confirmation Deed” was executed and delivered. In…
2Cases cited22 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Weiss v. WeinerSupreme Court of the United States · 1929
- Anderson v. HelveringSupreme Court of the United States · 1940
17 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Johnson v. CommissionerUnited States Tax Court · 1979
- Estate of Arnett v. CommissionerUnited States Tax Court · 1958
- O. H. Deshotels, Jr., and Fay C. Deshotels v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Edelman v. United StatesUnited States Court of Claims · 1964
13 more not listed; retrieve them via the Exa API.