Legal Opinion

Doyle v. Commissioner

United States Board of Tax Appeals

Decided February 9, 1938No. Docket No. 82713Published

Petitioner assigned on December 18, 1931, for $10,500 all his interest in fees to become payable in the future to a dissolved law partnership in connection with matters of one client pursuant to an agreement of the same date made with one of his former law partners. On June 17, 1932, petitioner received the $10,500. Petitioner did not receive this amount as a recovery of capital contribution to the partnership or as compensation for his share of good will of the partnership.

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Petitioner assigned on December 18, 1931, for $10,500 all his interest in fees to become payable in the future to a dissolved law partnership in connection with matters of one client pursuant to an agreement of the same date made with one of his former law partners. On June 17, 1932, petitioner received the $10,500. Petitioner did not receive this amount as a recovery of capital contribution to the partnership or as compensation for his share of good will of the partnership. The amount represented payment to petitioner of his share of fees to be received for services he had performed while a…

1Opinion of the Court

RICHARD S. DOYLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Doyle v. Commissioner

Docket No. 82713.

United States Board of Tax Appeals

37 B.T.A. 323; 1938 BTA LEXIS 1056;

February 9, 1938, Promulgated

Petitioner assigned on December 18, 1931, for $10,500 all his interest in fees to become payable in the future to a dissolved law partnership in connection with matters of one client pursuant to an agreement of the same date made with one of his former law partners. On June 17, 1932, petitioner received the $10,500. Petitioner did not receive this amount as a recovery of capital…

2Cases cited1 opinion

  1. Doyle v. CommissionerUnited States Board of Tax Appeals · 1938

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