Legal Opinion

Gordon v. Commissioner

United States Tax Court

Decided May 6, 1948No. Docket No. 12956PublishedCited by 12 opinions

Income -- Compensation for Extended Services -- Section 107 (a). -- Period includes that during which efforts were unsuccessful.

1Opinion of the Court

OPINION.

Murdoch, Judge:

The difference between the parties is on a narrow issue. The respondent concedes that the $37,500 received by the petitioner was for personal services, it was the total compensation received by him, and it was received in one taxable year. The only difference is as to the period covered by the personal services for which the compensation was paid. The respondent argues that the period of services hp.ga.n on July 13, 1943, when the petitioner made the introduction of the broker to Place, which ultimately resulted in the sale on March 20, 1944, less than 36 months later.…

2Cited by12 opinions

  1. Galt v. CommissionerUnited States Tax Court · 1953
  2. Ranz v. CommissionerUnited States Tax Court · 1958
  3. Finley v. CommissionerUnited States Tax Court · 1960
  4. Jillson v. CommissionerUnited States Tax Court · 1954
  5. Finley v. CommissionerUnited States Tax Court · 1960

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