Barrett v. Commissioner
United States Tax Court
Held, that the $ 12,000 received by petitioner during the taxable year 1969, under a contract entered into between Philip Carey and petitioner on Jan. 5, 1962, was not self-employment income subject to tax under sec. 1401, I.R.C. 1954.
1Opinion of the Court
opinion
Bruce, Judge:
Respondent determined a deficiency in self-employment tax of the petitioners for the calendar year 1969 in the amount of $538.20. The only issue is whether $12,000 received by the petitioner, Herbert Barrett, under a contract entered into between the Philip Carey Manufacturing Co. and petitioner on January 5,1962, is self-employment income subject to tax under section 1401 of the Internal Revenue Code of 1954.1 The facts are stipulated and the stipulation of facts together with the exhibits attached thereto are incorporated herein by this reference.
The petitioners are, and…
2Cases cited6 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Lewellyn v. FrickSupreme Court of the United States · 1925
- Bowers, Collector of Internal Revenue v. New York & Albany Lighterage Co. Same v. Seaman. Same v. FullerSupreme Court of the United States · 1927
- Anna J. McDowell v. Abraham A. Ribicoff, Secretary of Health, Welfare and EducationCourt of Appeals for the Third Circuit · 1961
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3Cited by36 opinions
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- Ditunno v. CommissionerUnited States Tax Court · 1983
- Robert E. Milligan v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
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