Legal Opinion

Poorman v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided December 4, 1942No. 10090PublishedCited by 35 opinions

1Opinion of the Court

STEPHENS, Circuit Judge.

This is a petition for the review of an order of the Board of Tax Appeals, and the sole question is whether a payment of money to the petitioner was a gift under the income tax laws as they were applicable for the taxable year of 1937. Both the Commissioner of Internal Revenue and the Board found the payment to be in the nature of compensation and not a gift.

Petitioner, an attorney at law, was employed on a monthly salary by the Los An-geles Gas and Electric Corporation, hereinafter called the Gas Company, for a period of seventeen years prior to January, 1937. A great…

2Cases cited7 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Bogardus v. CommissionerSupreme Court of the United States · 1937
  3. Noel v. ParrottCourt of Appeals for the Fourth Circuit · 1926
  4. Commissioner of Internal Revenue v. BoeingCourt of Appeals for the Ninth Circuit · 1939
  5. Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942

2 more not listed; retrieve them via the Exa API.

3Cited by35 opinions

  1. Gladys W. Simpson v. United StatesCourt of Appeals for the Seventh Circuit · 1958
  2. Silverman v. CommissionerUnited States Tax Court · 1957
  3. Flood v. United StatesCourt of Appeals for the First Circuit · 1943
  4. Eva L. Gaugler, on Behalf of Herself and as Under the Last Will and Testament of Raymond C. Gaugler, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1963
  5. State v. PollockSupreme Court of Alabama · 1948

30 more not listed; retrieve them via the Exa API.

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