Schneer v. Commissioner
United States Tax Court
P referred clients to law firm A, by whom he was employed as an associate. He received a salary and a percentage of fees generated by the referred clients. P then left law firm A and became a partner of law firm B and agreed to turn over any income from his practice of law to B from that date forward.
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P referred clients to law firm A, by whom he was employed as an associate. He received a salary and a percentage of fees generated by the referred clients. P then left law firm A and became a partner of law firm B and agreed to turn over any income from his practice of law to B from that date forward. After he became a partner of B, P consulted concerning clients he had referred to A. With one exception, the fees were earned after P left A. When fees were received from A, P turned them over to B. B accounted for and reported the fees, for tax purposes, as partnership income which P reported…
1Opinion of the Court
GERBER, Judge:
Respondent, by means of separate notices of deficiency, determined deficiencies in Federal income tax for petitioners’ 1984 and 1985 taxable years in the amounts of $49,708 and $25,252, respectively. Respondent, in both years, also determined additions to tax under section 6653(a)(1)1 and an additional 50-percent interest on $45,437 of the 1984 deficiency and on $25,252 of the 1985 deficiency under section 6653(a)(2). Respondent also determined additions to tax under section 6661 and increased interest under section 6621(c) for both taxable years. By agreement, the parties have…
2Cases cited37 opinions
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