Martin v. Commissioner

opinion.

Bruce, Judge:

The respondent determined a deficiency in the income tax of the petitioners for the calendar year 1957 in the amount of $1,800.24.

The statutory notice was issued February 23, 1961. The petition herein was filed May 19, 1961, and respondent’s answer was filed July 10, 1961. The principal issue presented by the pleadings is whether petitioners were entitled to apportion a fee of $20,000, received in 1957, over the years 1951 through 1957, under the provisions of sections 1301 to 1307, inclusive, of the Internal Revenue Code of 1954. Other issues arose out of the…