Olson v. Commissioner
United States Board of Tax Appeals
Under a resolution of a corporation dated March 13, 1917, 40 shares of the capital stock of the corporation were issued annually to a trustee as additional compensation to each of the petitioners. The trustee was to hold the shares for a period of five years.
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Under a resolution of a corporation dated March 13, 1917, 40 shares of the capital stock of the corporation were issued annually to a trustee as additional compensation to each of the petitioners. The trustee was to hold the shares for a period of five years. The trustee paid the dividends on the stock as received by him to the petitioners and, at the end of the five-year period in 1922, caused to be issued to each of the petitioners a certificate for 200 shares of the stock. Held, that each of the petitioners was liable to income tax in 1922 upon the fair market value of the 200 shares of…
1Opinion of the Court
*707OPINION.
Smith:
In so far as material hereto, section 213 of the Revenue Act of 1921 provides:
That * * * the term “ gross income ”—(a) Includes gains, profits, and income derived from salaries, wages, or compensation for personal service * * * of whatever kind and in whatever form paid * * * and income derived from any source whatever. The amount of all such items * * * shall be included in the gross income for the taxable year in which received by the taxpayer * * *.
The petitioners’ first allegation of error is to the effect that they received additional compensation in the form of money or…
2Cases cited2 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Jackson v. SmietankaCourt of Appeals for the Seventh Circuit · 1921
3Cited by7 opinions
- Burns v. CommissionerUnited States Board of Tax Appeals · 1934
- Chaplin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1943
- Hegra Note Corp. v. CommissionerUnited States Tax Court · 1966
- Omaha Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- Olson v. CommissionerUnited States Board of Tax Appeals · 1931
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