Legal Opinion

Woodward v. Commissioner

United States Tax Court

Decided September 30, 1968No. Docket No. 3573-66Published

Petitioner contracted in 1956 to perform the professional engineering services required for the construction of a sewerage system and treatment plant for 7 1/2 percent of the cost, to be paid, first, $ 2,500 for preliminary plans, second, after voter approval of the project, 65 percent, less the preliminary payment, for detailed plans, and third, 35 percent for supervising construction. Petitioner carried out the contract.

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Petitioner contracted in 1956 to perform the professional engineering services required for the construction of a sewerage system and treatment plant for 7 1/2 percent of the cost, to be paid, first, $ 2,500 for preliminary plans, second, after voter approval of the project, 65 percent, less the preliminary payment, for detailed plans, and third, 35 percent for supervising construction. Petitioner carried out the contract. Voter approval was secured in November 1961. Petitioner received $ 7,500 before 1963. In 1963 he received $ 46,125 for detailed plans and $ 24,939.27 for supervising…

1Opinion of the Court

Walter L. Woodward and Bernice A. Woodward, Petitioners v. Commissioner of Internal Revenue, Respondent

Woodward v. Commissioner

Docket No. 3573-66

United States Tax Court

50 T.C. 982; 1968 U.S. Tax Ct. LEXIS 54;

September 30, 1968, Filed

Decision will be entered for the respondent.

Petitioner contracted in 1956 to perform the professional engineering services required for the construction of a sewerage system and treatment plant for 7 1/2 percent of the cost, to be paid, first, $ 2,500 for preliminary plans, second, after voter approval of the project, 65 percent, less the preliminary payment, for…

2Cases cited6 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Sanford v. CommissionerUnited States Tax Court · 1968
  3. Lum v. CommissionerUnited States Tax Court · 1949
  4. Woodward v. CommissionerUnited States Tax Court · 1968
  5. Englar's Estate v. CommissionerCourt of Appeals for the Second Circuit · 1948

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