Stevens Bros. & Miller-Hutchinson Co. v. Commissioner
United States Tax Court
Division of Profits -- Money Furnished at Risk of Job. -- A taxpayer contractor is not taxable with entire profits from a job where, in order to obtain required $ 75,000 of funds subrogated to the rights of all creditors, it agreed that the corporation furnishing the funds should have one-half of the profits from the job.
1Opinion of the Court
Stevens Brothers and The Miller-Hutchinson Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Stevens Bros. & Miller-Hutchinson Co. v. Commissioner
Docket No. 49117
United States Tax Court
24 T.C. 953; 1955 U.S. Tax Ct. LEXIS 111;
August 29, 1955, Filed
Decision will be entered under Rule 50.
Division of Profits -- Money Furnished at Risk of Job. -- A taxpayer contractor is not taxable with entire profits from a job where, in order to obtain required $ 75,000 of funds subrogated to the rights of all creditors, it agreed that the corporation furnishing the funds should have…
2Cases cited6 opinions
- Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
- Miles-Conley Co. v. CommissionerUnited States Tax Court · 1948
- Dorzback v. Collison, Collector of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- De Reitzes-Marienwert v. CommissionerUnited States Tax Court · 1954
- Stevens Bros. & Miller-Hutchinson Co. v. CommissionerUnited States Tax Court · 1955
1 more not listed; retrieve them via the Exa API.