Irving Sachs v. Commissioner of Internal Revenue

MATTHES, Circuit Judge.

The question is whether the amounts paid by Shu-Stiles, Inc., a Missouri corporation, to discharge a fine imposed upon petitioner, who was a shareholder and the president of the corporation, constitute income'taxable to petitioner under § 22(a), § 115(a) Internal Revenue Code, 1939, 26 U.S.C.A. §§ 22(a) 115(a), § 61, § 316 Internal Revenue Code, 1954, 26 U.S.C.A. §§ 61, 316. The Tax Court sustained respondent’s determination that for the years 1951 through 1955 there were deficiencies in petitioner’s income tax totaling $21,651.69. See 32 T.C. 815. It is this decision…