Knowland v. Commissioner
United States Board of Tax Appeals
The petitioner acquired by bequest in 1921 two claims against the United States arising out of the detention in 1892 of certain whaling vessels, on which he recovered judgment and received payment in 1926 and 1928. The recoveries were measured by the average price of the probable catch the vessels might have made if not detained. The crews were to be paid for their services certain shares of the proceeds of the catch.
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The petitioner acquired by bequest in 1921 two claims against the United States arising out of the detention in 1892 of certain whaling vessels, on which he recovered judgment and received payment in 1926 and 1928. The recoveries were measured by the average price of the probable catch the vessels might have made if not detained. The crews were to be paid for their services certain shares of the proceeds of the catch. Held that the recoveries constituted taxable income and that in the absence of evidence showing that a segregation had been made of the shares of the crews and such parts held…
1Opinion of the Court
J. R. KNOWLAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Knowland v. Commissioner
Docket Nos. 45198, 60979.
United States Board of Tax Appeals
29 B.T.A. 618; 1933 BTA LEXIS 913;
December 21, 1933, Promulgated
The petitioner acquired by bequest in 1921 two claims against the United States arising out of the detention in 1892 of certain whaling vessels, on which he recovered judgment and received payment in 1926 and 1928. The recoveries were measured by the average price of the probable catch the vessels might have made if not detained. The crews were to be paid for their services…
2Cases cited1 opinion
- Knowland v. CommissionerUnited States Board of Tax Appeals · 1933