Sproull v. Commissioner
United States Tax Court
A corporation paid over to a trustee in 1945 the sum of $ 10,500 as compensation for past services rendered by petitioner. The trustee was directed to hold, invest and pay over this sum to petitioner or his estate in two installments in 1946 and 1947. Held, the entire trust fund was income to petitioner in 1945.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The Commissioner included in petitioner’s 1945 taxable income as bonus income the sum of $10,500 paid by Brainard Steel Corporation to the Union Savings and Trust Company of Warren, Ohio, trustee under the agreement of December 26,1945.
Petitioner contends the respondent taxed him in the wrong year and that instead of being taxable on the full $10,500 in 1945 he was properly taxable in 1946 and 1947 on the amounts paid him by the trustee in those years.
Neither the stipulated facts nor the oral testimony establish whether petitioner made his returns on a cash basis.…
2Cases cited3 opinions
- Brodie v. CommissionerUnited States Tax Court · 1942
- Deupree v. CommissionerUnited States Tax Court · 1942
- Amend v. CommissionerUnited States Tax Court · 1949
3Cited by47 opinions
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Miller v. HellerDistrict Court, S.D. New York · 1996
- Kuehner v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1954
- Stiles v. CommissionerUnited States Tax Court · 1978
- Watson v. CommissionerUnited States Tax Court · 1978
42 more not listed; retrieve them via the Exa API.