Hanna v. Commissioner

STEPHENS, Circuit Judge.

The Commissioner of Internal Revenue found deficiencies in income tax returns of Byron C. Hanna and his wife, Daisy May Hanna, for the year 1940. They each filed a petition with the Tax Court of the United States, alleging error in the denial of the application of Section 107 of the Internal Revenue Code1 to a fee re*137ceived in 1940 by a law partnership of which Mr. Hanna was an equal partner with Mr. Harold Morton and accounted for by Mr. and Mrs. Hanna as community income received over a period in excess of five years by the partnership. The proceedings under the…