Chicago Title & Trust Co. v. Commissioner
United States Board of Tax Appeals
Proceeds of a contract entered into in a prior year by petitioner's decedent for attorney fees for carrying on certain litigation, paid in the taxable years to a trust which petitioner's decedent had created in a prior year, held taxable as the income of petitioner's decedent notwithstanding the prior assignments to the trust of decedent's interest therein.
1Opinion of the Court
OPINION.
Black :
Petitioner seeks the redetermination of deficiencies in income tax against Charles H. Aldrich for the calendar year 1928 and the period January 1 to April 13, 1929, inclusive, in the respective amounts of $34,186.81 and $12,046.86; and also a deficiency in income tax against the estate of Charles H. Aldrich, deceased, for the period April 14 to December 31, 1929, in the amount of $46.88.
Only questions of law are involved, namely, (1) whether certain attorney fees earned by Charles H. Aldrich during his lifetime are income to Aldrich and his estate and therefore taxable to…
2Cases cited10 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Corliss v. BowersSupreme Court of the United States · 1930
- Poe v. SeabornSupreme Court of the United States · 1930
- Ginsburg v. Bull Dog Auto Fire Insurance Ass'nIllinois Supreme Court · 1928
- L. P. Larson, Jr., Co. v. Wm. Wrigley, Jr., Co.Court of Appeals for the Seventh Circuit · 1918
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3Cited by2 opinions
- Chicago Title & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1935
- Eubank v. CommissionerUnited States Board of Tax Appeals · 1939