Clarke v. Commissioner
United States Tax Court
During 1951, petitioner was one of four trustees of a Massachusetts real estate trust and received compensation in the amount of $ 3,000 for her services as trustee. Held, petitioner was in the trade or business of being a trustee and such sum constituted earnings from self-employment within the meaning of section 481 of the 1939 Code, and was therefore subject to the self-employment tax.
1Opinion of the Court
Cresence E. Clarke, Petitioner, v. Commissioner of Internal Revenue, Respondent
Clarke v. Commissioner
Docket No. 55486
United States Tax Court
27 T.C. 861; 1957 U.S. Tax Ct. LEXIS 256;
February 26, 1957, Filed
Decision will be entered for the respondent.
During 1951, petitioner was one of four trustees of a Massachusetts real estate trust and received compensation in the amount of $ 3,000 for her services as trustee. Held, petitioner was in the trade or business of being a trustee and such sum constituted earnings from self-employment within the meaning of section 481 of the 1939 Code, and was…
2Cases cited7 opinions
- United States v. PyneSupreme Court of the United States · 1941
- Philbin v. CommissionerUnited States Tax Court · 1956
- United States v. GriswoldCourt of Appeals for the First Circuit · 1941
- Commissioner of Internal Revenue v. Valentine E. MacY Jr., Commissioner of Internal Revenue v. J. Noel MacY and Elena Kohler MacYCourt of Appeals for the Second Circuit · 1954
- Clarke v. CommissionerUnited States Tax Court · 1957
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