Whitman v. Commissioner of Internal Revenue

This appeal involves taxpayer’s income tax liability for the years 1941 and 1943. Petitioner is a practicing attorney. During the period of years from 1937 to 1943, inclusive, he kept his books and records on the cash receipts and disbursements basis. The question presented is whether amounts received on account of fees for services rendered a receiver in liquidation proceedings were compensation for personal services when received, and whether he is entitled to tax reduction under § 107 Internal Revenue Code, as amended, 26 U.S. C.A. § 107.

The Tax Court upheld the determination of the…