Legal Opinion

Tufts v. Commissioner

United States Tax Court

Decided February 18, 1946No. Docket No. 7155PublishedCited by 5 opinions

Income -- Year. -- A taxpayer on a cash basis was not in actual or constructive receipt of additional salary which the employer did not accrue or credit to his account in 1942 and did not pay until 1943 because of Government regulations on increased salaries.

1Opinion of the Court

OPINION.

Murdock, Judge-.

The Commissioner determined a deficiency of' $5,782.54 in the petitioner’s income tax for the calendar year 1943. One of the adjustments which he made in determining that deficiency was to include in income $8,333.34 representing salary received by the petitioner in May 1943 from Allied Chemical & Dye Corporation. The ¡petitioner assigns this action of the Commissioner as error. The facts have been stipulated. The stipulation is adopted as our findings of ¡fact.

The petitioner is an individual who filed his returns for the calendar years 1942 and 1943 with the collector…

2Cited by5 opinions

  1. Hooker Electrochemical Co. v. CommissionerUnited States Tax Court · 1947
  2. Hooker Electrochemical Co. v. CommissionerUnited States Tax Court · 1947
  3. Hooker Electrochemical Co. v. CommissionerUnited States Tax Court · 1947
  4. John H. Soller & Margaret W. Soller v. CommissionerUnited States Tax Court · 1949
  5. Tufts v. CommissionerUnited States Tax Court · 1946

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