Legal Opinion

Fine v. War Contracts Price Adjustment Board

United States Tax Court

Decided October 7, 1947No. Docket No. 148-RPublished

Petitioner, since 1939, has been engaged in business as manufacturers' agent. In 1943 he received commissions of $ 36,598.51, based upon the amounts of contracts for commodities having a war-end use. Of such amount, $ 19,131.44 was based on amounts of contracts procured by him for his principals and $ 17,467.07 was compensation for field services in connection with contracts of his principal.

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Petitioner, since 1939, has been engaged in business as manufacturers' agent. In 1943 he received commissions of $ 36,598.51, based upon the amounts of contracts for commodities having a war-end use. Of such amount, $ 19,131.44 was based on amounts of contracts procured by him for his principals and $ 17,467.07 was compensation for field services in connection with contracts of his principal. Held, (1) since the sum of $ 17,467.07 was not contingent upon the procurement by petitioner of the contracts or subcontracts upon the amount of which the compensation was based, such amount, although…

1Opinion of the Court

Leon Fine, d/b/a Leon Fine & Company, Petitioner, v. War Contracts Price Adjustment Board, Respondent

Fine v. War Contracts Price Adjustment Board

Docket No. 148-R.

United States Tax Court

9 T.C. 600; 1947 U.S. Tax Ct. LEXIS 76;

October 7, 1947, Promulgated

Petitioner, since 1939, has been engaged in business as manufacturers' agent. In 1943 he received commissions of $ 36,598.51, based upon the amounts of contracts for commodities having a war-end use. Of such amount, $ 19,131.44 was based on amounts of contracts procured by him for his principals and $ 17,467.07 was compensation for field…

Also in this document: Dissent.

2Cases cited3 opinions

  1. Wolff & Phillips v. MacauleyUnited States Tax Court · 1947
  2. Iverson & Laux, Inc. v. ForrestalUnited States Tax Court · 1946
  3. Fine v. War Contracts Price Adjustment BoardUnited States Tax Court · 1947

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