Woodward v. Commissioner
United States Tax Court
Petitioner contracted in 1956 to perform the professional engineering services required for the construction of a sewerage system and treatment plant for 7 1/2 percent of the cost, to be paid, first, $ 2,500 for preliminary plans, second, after voter approval of the project, 65 percent, less the preliminary payment, for detailed plans, and third, 35 percent for supervising construction. Petitioner carried out the contract.
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Petitioner contracted in 1956 to perform the professional engineering services required for the construction of a sewerage system and treatment plant for 7 1/2 percent of the cost, to be paid, first, $ 2,500 for preliminary plans, second, after voter approval of the project, 65 percent, less the preliminary payment, for detailed plans, and third, 35 percent for supervising construction. Petitioner carried out the contract. Voter approval was secured in November 1961. Petitioner received $ 7,500 before 1963. In 1963 he received $ 46,125 for detailed plans and $ 24,939.27 for supervising…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in income tax of the petitioners in the amounts of $8,296.17 and $325.94 for 1963 and 1964, respectively. Two issues are presented for decision, (1) whether the petitioners may apply section 1301 of the Internal Revenue Code of 1954, as effective in 1963, in computing the tax with respect to certain earnings of Walter L. Woodward received in 1963, and (2) whether respondent erred in the disallowance of certain business expenses claimed as deductions in 1963 and 1964.
FINDINGS OF FACT
The stipulated facts, together with the exhibits attached to the…
2Cases cited5 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- Lum v. CommissionerUnited States Tax Court · 1949
- Englar's Estate v. CommissionerCourt of Appeals for the Second Circuit · 1948
- Shaffer v. CommissionerUnited States Tax Court · 1957
3Cited by17 opinions
- Andress v. CommissionerUnited States Tax Court · 1969
- Robinson v. CommissionerUnited States Tax Court · 1968
- Finney v. CommissionerUnited States Tax Court · 1980
- Nor-Cal Adjusters v. CommissionerUnited States Tax Court · 1971
- Andress v. CommissionerUnited States Tax Court · 1969
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