Miller v. Commissioner
United States Tax Court
The petitioner, a member of a partnership, was the managing partner of the firm's Paris office for a period of time and received payments from the partnership attributable to such period. Held, some of the payments were guaranteed payments within the meaning of sec. 707(c), I.R.C. 1954, and are fully excludable from gross income under sec. 911, I.R.C. 1954, as income from sources without the United States.
1Opinion of the Court
Andrew O. Miller, Jr., and Jeanne W. Miller, Petitioners v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket No. 3228-66
United States Tax Court
52 T.C. 752; 1969 U.S. Tax Ct. LEXIS 82;
August 6, 1969, Filed
Decision will be entered under Rule 50.
The petitioner, a member of a partnership, was the managing partner of the firm's Paris office for a period of time and received payments from the partnership attributable to such period. Held, some of the payments were guaranteed payments within the meaning of sec. 707(c), I.R.C. 1954, and are fully excludable from gross income…
2Cases cited8 opinions
- Miller v. CommissionerUnited States Tax Court · 1969
- Falconer v. CommissionerUnited States Tax Court · 1963
- Lloyd v. CommissionerUnited States Board of Tax Appeals · 1929
- Thomas Browne Foster v. United StatesCourt of Appeals for the Second Circuit · 1964
- Benfer v. CommissionerUnited States Tax Court · 1965
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