Willkie v. Commissioner of Internal Revenue

HAMILTON, Circuit Judge.

This is a proceeding to review a decision 0f the Board of Tax Appeals. The question is whether the petitioner, Herman Frederick Willkie, received $15,000.00 during the calendar year 1927, as additional compensation for services rendered to Hiram Walker & Sons, Inc., or whether the sum so received was a gift.

™ , ,, , The Commissioner held the sum to be compensatjon constituting a part of the titioner>s inCome, an/ declared a defid t¿ of $4,427.73. The Board of Tax AppeaIs sust¡Ined the Commissioner, We ^ L The facts are nQt ^ , u , u £ n dispute and are substantially as…