Field v. Commissioner
United States Board of Tax Appeals
1. Held that certain income from a trust fund received by the petitioner's wife pursuant to a formal and complete assignment by him to her of his interest therein should not be included in the petitioner's taxable income. 2. Where attorney's fees paid in installments pursuant to a contingent-fee contract for services which resulted in a decree for the petitioner under which income which otherwise he could not have received was paid to him, it is held, under the peculiar…
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1. Held that certain income from a trust fund received by the petitioner's wife pursuant to a formal and complete assignment by him to her of his interest therein should not be included in the petitioner's taxable income. 2. Where attorney's fees paid in installments pursuant to a contingent-fee contract for services which resulted in a decree for the petitioner under which income which otherwise he could not have received was paid to him, it is held, under the peculiar circumstances of this case, that the payments should be deducted in computing net income for the year in which such payments…
1Opinion of the Court
*723OPINION.
GREen:
The first question raised in this proceeding is whether certain income from a trust fund, received by the petitioner’s wife pursuant to a formal and complete assignment by him to her of his right or interest, is nevertheless taxable to the petitioner.
The right of the petitioner in the trust was clearly and definitely established and determined by the courts of the State of Illinois, and as to property rights, its decree is unquestionably binding on this Board.
From this decree it is apparent that as to the two-fifths trust, the petitioner’s right or interest is adjudged to be…
2Cited by9 opinions
- Bell's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- Drake v. CommissionerUnited States Board of Tax Appeals · 1934
- Bell's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- Browning v. CommissionerUnited States Board of Tax Appeals · 1929
- Chicago Title & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1935
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