Nast v. Commissioner
United States Tax Court
Where a physician accumulated charges for his services to a patient over a period in excess of 36 months, payments on account made during the period must be taken into account under section 107 (a), I. R. C., in determining whether compensation received or accrued in one taxable year was at least 80 per cent of the total compensation for services covering the period.
1Opinion of the Court
OPINION.
HaRLan, Judge:
In their income tax returns for 1943 the petitioners claimed the benefits of section 107 (a) of the Internal Revenue Code2 with respect to the $1,946 received on September 4, 1943, by Jerome Nast, a family physician, as payment in full for services performed for one family to that date.
The petitioners contend that the “period” involved began April 22, 1939, and ended September 4,1943, a period of more than 36 months; that the payment of $1,946 made September 4, 1943, covered services for the entire period and that the payments on account made prior to September 4,1943,…
2Cases cited1 opinion
- Civiletti v. CommissionerUnited States Tax Court · 1944
3Cited by20 opinions
- Lum v. CommissionerUnited States Tax Court · 1949
- Spears v. CommissionerUnited States Tax Court · 1946
- Loew v. CommissionerUnited States Tax Court · 1952
- Pierce v. CommissionerUnited States Tax Court · 1955
- Ranz v. CommissionerUnited States Tax Court · 1958
15 more not listed; retrieve them via the Exa API.