Legal Opinion

Parkford v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided January 19, 1943No. 10132PublishedCited by 25 opinions

1Opinion of the Court

HEALY, Circuit Judge.

The petition is for review of a decision of the Board of Tax Appeals. It involves an asserted deficiency in income taxes for the year 1936.

Two main questions are presented, (1) whether a contingent fee of the taxpayer for personal services, paid to and received by his trustee in bankruptcy in 1936, was accruable by the taxpayer as income in that year or in the previous year, 1935; and (2) whether a like fee, accruing after bankruptcy and paid to the trustee in 1936, was or was not income to the taxpayer.

1. In 1935 the taxpayer was employed by the president of Universal…

2Cases cited7 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  4. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  5. Corliss v. BowersSupreme Court of the United States · 1930

2 more not listed; retrieve them via the Exa API.

3Cited by25 opinions

  1. Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  2. United States v. Randolph GeorgeCourt of Appeals for the Ninth Circuit · 2005
  3. Estate of Delman v. CommissionerUnited States Tax Court · 1979
  4. In the Matter of Laurence Semel, Bankrupt. Laurence SemelCourt of Appeals for the Third Circuit · 1969
  5. Bloomfield v. CommissionerUnited States Tax Court · 1969

20 more not listed; retrieve them via the Exa API.

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