Legal Opinion

Bruno v. Commissioner

United States Tax Court

Decided November 20, 1978No. Docket No. 7284-76Published

Petitioner sought to apply the maximum tax on earned income under sec. 1348 to the entire net profits from her bail bonding business. Held, such profits are subject to the maximum tax on earned income since capital is not a material income-producing factor in petitioner's business within the meaning of sec. 1348.

1Opinion of the Court

Dorothy Bruno, Petitioner v. Commissioner Of Internal Revenue, Respondent

Bruno v. Commissioner

Docket No. 7284-76

United States Tax Court

71 T.C. 191; 1978 U.S. Tax Ct. LEXIS 27;

November 20, 1978, Filed

Decision will be entered under Rule 155.

Petitioner sought to apply the maximum tax on earned income under sec. 1348 to the entire net profits from her bail bonding business. Held, such profits are subject to the maximum tax on earned income since capital is not a material income-producing factor in petitioner's business within the meaning of sec. 1348.

Charles C. Shafer, Jr., for the petitioner.

John…

2Cases cited14 opinions

  1. United States v. RyderSupreme Court of the United States · 1884
  2. Sperapani v. CommissionerUnited States Tax Court · 1964
  3. Rousku v. CommissionerUnited States Tax Court · 1971
  4. Bruno v. CommissionerUnited States Tax Court · 1978
  5. Allied Fidelity Corporation, F/k/a, William E. Roe, Allied Agents, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978

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