Samuel J. Chase and Jeannette S. Chase v. Commissioner of Internal Revenue

JAMES ALGER FEE, Circuit Judge.

This case involves a single issue of law. The facts are all established by stipulation of the parties.

The question is whether the taxpayers 1 are entitled to have the sum of $22,-500, allotted to Samuel J. Chase by the California Probate Court for extraordinary services rendered to the estate of George L. Leiter, deceased, and received during that year, taxed under Section 107 (a) of the Internal Revenue Code of 1939. 2

Chase was one of the executors of the Leiter estate. He was a lawyer. He rendered extraordinary services in connection with the case of Chase v.…