Hall v. Commissioner of Internal Revenue

PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals; and the question involved is whether a payment of $50,-000 made to taxpayer was a gift or additional compensation for services rendered. Taxpayer is a patent attorney who over a period of years had rendered services to the Universal Oil Products Company, a corporation whose chief property, consisted of certain patents and patent rights. In 1931 the stockholders of that corporation sold their stock for $25,000,000 to the United Gasoline Corporation. Shortly prior to the transfer, however, and in…