Jacobs v. Commissioner
United States Board of Tax Appeals
Amount voted by directors of corporation to petitioner in 1925, payment to be made "at such time as in the opinion of the directors the corporation's cash position will permit," was accrued on books of corporation in 1925, but was not paid to petitioner, who files his returns on the cash basis. Held, on the evidence, the amount was not constructively received by petitioner in 1925.
1Opinion of the Court
*1168ORINION.
Matthews :
The respondent has determined that the sum of $50,-000 was constructively received by the petitioner in 1925 and has included that amount in the petitioner’s gross income, although payment was not actually received in that year. The petitioner claims that the amount in question, which represents a commission voted by the directors to be paid to petitioner when the financial position of the Crosstown Realty Corporation warranted, could not be paid until authorized by the directors, and that it was not available to the petitioner in the taxable year, although it was credited…
2Cited by14 opinions
- Jerome Castree Interiors, Inc. v. CommissionerUnited States Tax Court · 1975
- Estate of Noel v. CommissionerUnited States Tax Court · 1968
- Estate of Snider v. CommissionerUnited States Tax Court · 1962
- Mott v. CommissionerUnited States Board of Tax Appeals · 1934
- Gaines v. CommissionerUnited States Tax Court · 1982
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