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