Legal Opinion

George E. Reynolds, Petition v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided November 7, 1957No. 7490_1PublishedCited by 5 opinions

1Opinion of the Court

SOPER, Circuit Judge.

This petition to review a decision of the Tax Court raises the question whether the taxpayer, who received the sum of $55,536 in 1942 for services rendered over a period of thirty-six months, is entitled, in computing his tax liability for the year, to spread the payment over the period in which the services were rendered under § 107(a) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 107(a). 1

The taxpayer was a sales agent in the Washington area for Marmon-Herrington Company, Inc., and for certain other manufacturers of automotive products. In this field he rendered…

2Cases cited6 opinions

  1. Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  2. Cowan v. Henslee, Collector of Internal Revenue. Klein v. Henslee, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
  3. Spears v. CommissionerCourt of Appeals for the Third Circuit · 1947
  4. Englar's Estate v. CommissionerCourt of Appeals for the Second Circuit · 1948
  5. Samuel J. Chase and Jeannette S. Chase v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957

1 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Maurice J. Breen and Alyce J. Breen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
  2. Ralph B. Wattley and Josephine R. Wattley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
  3. Wattley v. CommissionerUnited States Tax Court · 1958
  4. Wattley v. CommissionerUnited States Tax Court · 1958
  5. Wattley v. CommissionerUnited States Tax Court · 1958

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