Legal Opinion

Bickford v. Commissioner

United States Board of Tax Appeals

Decided April 28, 1936No. Docket Nos. 54583, 55005Published

Held that payments made by stockholders of a corporation to its former employees in "appreciation" of past services to the corporation, out of the proceeds of the sale by such stockholders of their stock, constituted taxable income to the employees and not gifts.

1Opinion of the Court

WALTER M. BICKFORD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

C. H. CHRISTENSEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bickford v. Commissioner

Docket Nos. 54583, 55005.

United States Board of Tax Appeals

34 B.T.A. 461; 1936 BTA LEXIS 695;

April 28, 1936, Promulgated

Held that payments made by stockholders of a corporation to its former employees in "appreciation" of past services to the corporation, out of the proceeds of the sale by such stockholders of their stock, constituted taxable income to the employees and not gifts.

A. N. Whitlock, Esq., for the…

2Cases cited2 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Bickford v. CommissionerUnited States Board of Tax Appeals · 1936

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