Morrison v. Commissioner
United States Tax Court
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
- Lum v. CommissionerUnited States Tax Court · 1949
- Whitman v. CommissionerUnited States Tax Court · 1948
- Morrison v. CommissionerUnited States Tax Court · 1949