Redpath v. Commissioner
United States Tax Court
Held: That net operating loss carry-back deduction of the petitioner for the year 1945 is unaffected by the fact that a fee received in 1947 is subject to the provisions of section 107 (a), I. R. C.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The sole question for determination in this proceeding is the amount of the petitioner’s net operating loss carry-back deduction for the year 1945.1 In 1947 the petitioner received a fee of $6,755.48 for personal services rendered as a trustee over a period of 41 months from April 1948 to September 1946. The parties do not disagree that the provisions of section 107 (a) of the Internal Revenue Code2 would apply to this compensation received by the petitioner in 1947, but they differ, however, as to the effect of the receipt of this income upon the petitioner’s net…
2Cases cited4 opinions
- Stallforth v. CommissionerUnited States Tax Court · 1946
- Thayer v. CommissionerUnited States Tax Court · 1949
- Ford v. CommissionerUnited States Tax Court · 1952
- Van Bergh v. CommissionerUnited States Tax Court · 1952
3Cited by7 opinions
- Ernest L. Wilkinson and Alice L. Wilkinson v. The United StatesUnited States Court of Claims · 1962
- Gadlow v. CommissionerUnited States Tax Court · 1968
- Payne v. United StatesUnited States Court of Claims · 1974
- Ernest L. Wilkinson and Alice L. Wilkinson v. The United StatesUnited States Court of Claims · 1962
- Gadlow v. CommissionerUnited States Tax Court · 1968
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