Legal Opinion

Mahler v. Commissioner

United States Tax Court

Decided September 17, 1954No. Docket No. 45231Published

1. Compensation earned in a prior year and allocated at that time to previous years under section 107, Internal Revenue Code of 1939, held, to require consideration in computation under section 107 for additional income of a later year both as inclusion in income and as tax paid thereon, as though it had been earned ratably over only those previous years included in the period of allocation of the later year's income. 2. Half of income allocable to previous years under…

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1. Compensation earned in a prior year and allocated at that time to previous years under section 107, Internal Revenue Code of 1939, held, to require consideration in computation under section 107 for additional income of a later year both as inclusion in income and as tax paid thereon, as though it had been earned ratably over only those previous years included in the period of allocation of the later year's income. 2. Half of income allocable to previous years under section 107 (a), Internal Revenue Code of 1939, held, properly attributable in earlier years to wife, as if joint returns had…

1Opinion of the Court

Benjamin Mahler and Julia F. Mahler, Petitioners, v. Commissioner of Internal Revenue, Respondent

Mahler v. Commissioner

Docket No. 45231

United States Tax Court

22 T.C. 1180; 1954 U.S. Tax Ct. LEXIS 104;

September 17, 1954, Filed September 17, 1954, Filed

Decision will be entered under Rule 50.

1. Compensation earned in a prior year and allocated at that time to previous years under section 107, Internal Revenue Code of 1939, held, to require consideration in computation under section 107 for additional income of a later year both as inclusion in income and as tax paid thereon, as though it had…

2Cases cited4 opinions

  1. Knox v. CommissionerUnited States Tax Court · 1948
  2. Stockly v. CommissionerUnited States Tax Court · 1954
  3. Thayer v. CommissionerUnited States Tax Court · 1949
  4. Mahler v. CommissionerUnited States Tax Court · 1954

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