Miller v. Commissioner
United States Tax Court
Petitioners, during the years 1962 through 1965, were husband and wife domiciled in a community property State. In each year the husband received retirement community income and also received commissions as sole proprietor of a real estate brokerage business.
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Petitioners, during the years 1962 through 1965, were husband and wife domiciled in a community property State. In each year the husband received retirement community income and also received commissions as sole proprietor of a real estate brokerage business. Held, for the purpose of computing the retirement income credit provided by sec. 37, I.R.C. 1954, capital was not a material income-producing factor in petitioner's business; held, further, "earned income" in such computation should be determined by reference to net profits from petitioner's business and sec. 1.37-2(a), Income Tax Regs.,…
1Opinion of the Court
Warren R. Miller, Sr., and Hilda B. Miller, Petitioners v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket Nos. 5332-66, 1529-67
United States Tax Court
51 T.C. 755; 1969 U.S. Tax Ct. LEXIS 190;
February 17, 1969, Filed
Decisions will be entered under Rule 50.
Petitioners, during the years 1962 through 1965, were husband and wife domiciled in a community property State. In each year the husband received retirement community income and also received commissions as sole proprietor of a real estate brokerage business. Held, for the purpose of computing the retirement income…
2Cases cited22 opinions
- United States v. SilkSupreme Court of the United States · 1947
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Hopkins v. BaconSupreme Court of the United States · 1930
- Eastern Air Lines, Inc., and National Airlines, Inc. v. Civil Aeronautics BoardCourt of Appeals for the D.C. Circuit · 1965
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