Schmidt v. Commissioner
United States Tax Court
Compensation allocable to 1942 under Internal Revenue Code, section 107, held taxable upon receipt in 1943 only to the reduced extent provided by the Current Tax Payment Act. William F. Knox, 10 T. C. 550.
1Opinion of the Court
OPINION.
Opper, Judge-.
Respondent determined a deficiency in petitioner’s income and victory tax liability for the year 1943 in the amount of $5,888.11.
The only litigated issue involves the interrelated effect of section 107 (a) of the Internal Revenue Code and the so-called “forgiveness” features (section 6) of the Current Tax Payment Act of 1943 upon income received in lump sums in 1943 for services rendered over a period of years including 1942 and 1943.
All of the facts have been stipulated and are hereby found accordingly. For purposes of this proceeding, they may be summarized as follows:
P…
2Cases cited1 opinion
- Knox v. CommissionerUnited States Tax Court · 1948
3Cited by3 opinions
- Thayer v. CommissionerUnited States Tax Court · 1949
- Schmidt v. CommissionerUnited States Tax Court · 1948
- Thayer v. CommissionerUnited States Tax Court · 1949