Bruno v. Commissioner
United States Tax Court
Petitioner sought to apply the maximum tax on earned income under sec. 1348 to the entire net profits from her bail bonding business. Held, such profits are subject to the maximum tax on earned income since capital is not a material income-producing factor in petitioner's business within the meaning of sec. 1348.
1Opinion of the Court
Forrester, Judge:
Respondent has determined deficiencies in petitioner’s Federal income tax for the taxable years 1973 and 1974 in the amounts of $6,890.70, and $10,488.98, respectively. Concessions having been made, the only issue remaining for our decision is whether, for purposes of section 1348,1 petitioner employs capital as a material income-producing factor in the business of writing bail bonds.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner Dorothy Bruno (petitioner) resided in Kansas City, Mo., at the time the petition was filed herein. Petitioner…
2Cases cited13 opinions
- United States v. RyderSupreme Court of the United States · 1884
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Rousku v. CommissionerUnited States Tax Court · 1971
- Allied Fidelity Corporation, F/k/a, William E. Roe, Allied Agents, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
- Hubbard-Ragsdale Co. v. DeanDistrict Court, S.D. Ohio · 1926
8 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Moore v. CommissionerUnited States Tax Court · 1979
- Gaudern v. CommissionerUnited States Tax Court · 1981
- John M. Friedlander and Corrine Friedlander v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- The United States v. L.J. And Marjorie Van DykeCourt of Appeals for the Federal Circuit · 1982
- Van Kalker v. CommissionerUnited States Tax Court · 1983
27 more not listed; retrieve them via the Exa API.