Parkford v. Commissioner
United States Board of Tax Appeals
1. A taxpayer, on the accrual basis, rendered services under two contingent contracts. Under one he became entitled to receive stock when the stock out of which he was to be paid became available to the one for whom the services were rendered.
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1. A taxpayer, on the accrual basis, rendered services under two contingent contracts. Under one he became entitled to receive stock when the stock out of which he was to be paid became available to the one for whom the services were rendered. Under the evidence it is held the right to receive this fee accrued on January 15, 1936, when the court approved the settlement making the stock available. 2. After approval of the agreement by the court but before the stock was delivered to the taxpayer, he was adjudicated a bankrupt. The stock, pursuant to order of the bankruptcy court, was delivered…
1Opinion of the Court
*467OPINION.
Mellott :
Petitioners contend that the fair market value of the Universal shares, if income at all, became income when the right to receive them accrued to Parkford, which, they say, occurred in 1935 rather than 1936. They point out that all of the services had been rendered prior to the stockholders’ meeting on December 23, 1935; argue that the corporation had “bound itself by the resolution, unconditionally, to deliver” the shares to Parkford; contend that his right to receive them then became absolute; and insist that the statement in the resolution to the effect that delivery to…
2Cases cited11 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- United States v. AndersonSupreme Court of the United States · 1926
6 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Bloomfield v. CommissionerUnited States Tax Court · 1969
- Martin v. CommissionerUnited States Tax Court · 1971
- B & L FARMS CO. v. United StatesDistrict Court, S.D. Florida · 1965
- Schneer v. CommissionerUnited States Tax Court · 1991
- Richardson v. United StatesDistrict Court, C.D. California · 1974
9 more not listed; retrieve them via the Exa API.