Legal Opinion

Morrison v. Commissioner

United States Tax Court

Decided May 4, 1949No. Docket Nos. 17227, 17228, 17229, 17352Published

Attorneys' fees received by petitioners in the taxable year 1943 as counsel for receivers, being less than 80 per cent of their total compensation, including amounts received in prior and subsequent years for continuous legal services in the same receivership, held not subject to apportionment under section 107. Ralph E. Lum, 12 T. C. 375, followed.

1Opinion of the Court

William J. Morrison, Jr., Individually and as Administrator of the Estate of Mabel D. Morrison, Deceased, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent

Morrison v. Commissioner

Docket Nos. 17227, 17228, 17229, 17352

United States Tax Court

12 T.C. 709; 1949 U.S. Tax Ct. LEXIS 212;

May 4, 1949, Promulgated

Decision will be entered for the respondent.

Attorneys' fees received by petitioners in the taxable year 1943 as counsel for receivers, being less than 80 per cent of their total compensation, including amounts received in prior and subsequent years for continuous legal…

2Cases cited3 opinions

  1. Lum v. CommissionerUnited States Tax Court · 1949
  2. Whitman v. CommissionerUnited States Tax Court · 1948
  3. Morrison v. CommissionerUnited States Tax Court · 1949

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