Myers v. Commissioner
United States Tax Court
1. Activities of one engaged in promoting the purchase of privately owned electric power facilities by public utility districts, prior to the creation of said districts by popular vote, do not constitute "services rendered" as that term is used in section 107, I. R. C. 2. A promoter contracted with public power generating corporations to act as a broker in the purchase of privately owned power distributing facilities.
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1. Activities of one engaged in promoting the purchase of privately owned electric power facilities by public utility districts, prior to the creation of said districts by popular vote, do not constitute "services rendered" as that term is used in section 107, I. R. C. 2. A promoter contracted with public power generating corporations to act as a broker in the purchase of privately owned power distributing facilities. Prior to the completion of the purchase the contemplated purchasers discovered their legal inability to take title to distributing facilities. Thereupon a new public corporation…
1Opinion of the Court
Harlan, Judge:
The Commissioner determined deficiencies in Federal income tax for the years 1940 and 1941 in the respective amounts of $123,209.49 and $223,662.30. Three questions are presented:(1) Whether the income received by the petitioner during the taxable years 1940 and 1941 under contracts with various public utility districts is subject to taxation under the limitations provided by section 107 of the Internal Revenue Code.(2) Whether the contract income received by the petitioner from the public utility districts for the years 1940 and 1941 constituted community income of petitioner…
Also in this document: Concurrence.
2Cases cited2 opinions
- Comfort v. City of TacomaWashington Supreme Court · 1927
- Keeble v. CommissionerUnited States Tax Court · 1943
3Cited by15 opinions
- Ranz v. CommissionerUnited States Tax Court · 1958
- Myers v. CommissionerUnited States Tax Court · 1949
- Finley v. CommissionerUnited States Tax Court · 1960
- Dall v. CommissionerUnited States Tax Court · 1954
- Dall v. CommissionerUnited States Tax Court · 1954
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