Everhart v. Commissioner
United States Board of Tax Appeals
Where petitioner, a representative of a certain company, purchased an interest or participation in a syndicate organized by such company at a price less than the basis upon which such interests were sold to others, the reduction in selling price amounting to his customary commission on sales of such interests to others, held the difference between the usual selling price and the amount paid by petitioner is not taxable income to petitioner.
1Opinion of the Court
OPINION.
McMai-ion:
This is a proceeding for the redetormination of an asserted deficiency in income tax for the year 1922 in the amount of $2,370.94.
The petitioner alleges that the respondent erred in taxing as income the amount of $162,078.77 as shown on Form 1099, information certificate, filed by H. F. Wilcox Oil & Gas Company for the calendar year 1922 instead of the amount of $153,580.48 reported by the petitioner in his income-tax return for the year 1922.
The petitioner is an individual residing at 920 Edgemere Court, in the City of Evanston, County of Cook, State of Illinois.
*319During the…
2Cases cited1 opinion
- Continental Insurance v. United StatesSupreme Court of the United States · 1922
3Cited by8 opinions
- Estate of Falese v. CommissionerUnited States Tax Court · 1972
- Eagan v. CommissionerUnited States Tax Court · 1953
- Estate of Falese v. CommissionerUnited States Tax Court · 1972
- Everhart v. CommissionerUnited States Board of Tax Appeals · 1932
- North American Coal Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
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