Underwood v. Commissioner
United States Board of Tax Appeals
During the taxable years ended February 29, 1924, and February 28, 1925, the petitioner rendered architectural and engineering services to the State of North Carolina under contracts by which he was to receive and did receive a percentage upon the appropriation made for each institution erecting a building during those years; under his contracts he devoted his entire time and attention to the work to be performed for the State and rendered the services subject to the control…
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During the taxable years ended February 29, 1924, and February 28, 1925, the petitioner rendered architectural and engineering services to the State of North Carolina under contracts by which he was to receive and did receive a percentage upon the appropriation made for each institution erecting a building during those years; under his contracts he devoted his entire time and attention to the work to be performed for the State and rendered the services subject to the control and direction of the "Joint Building Commission"; he employed his own draftsmen and office force and paid them out of…
1Opinion of the Court
*1121OPINION.
Smith :
The principal point involved in this proceeding is whether the petitioner is exempt from income tax upon the fees or commissions received by him for services performed during the fiscal years ended February 29, 1924, and February 28, 1925, in the respective amounts of $68,080.60 and $44,666.15. These commissions were paid to him by the State of North Carolina under certain contracts entered into between the petitioner and the State for the performance of architectural and engineering services. The petitioner claims that he is exempt from income tax in respect of these fees and…
2Cases cited1 opinion
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
3Cited by6 opinions
- REID v. COMMISSIONERUnited States Board of Tax Appeals · 1933
- Modjeski v. CommissionerUnited States Board of Tax Appeals · 1933
- Hall v. CommissionerUnited States Board of Tax Appeals · 1936
- Hennessey v. Comm'rUnited States Tax Court · 2007
- Modjeski v. CommissionerUnited States Board of Tax Appeals · 1933
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