Mattox v. Commissioner
United States Tax Court
Income from certain contracts payable to petitioner was payable to him because he owned substantially all the stock of a corporation which was one of the parties to one of the contracts and a party in interest to the other contract.
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Income from certain contracts payable to petitioner was payable to him because he owned substantially all the stock of a corporation which was one of the parties to one of the contracts and a party in interest to the other contract. Held, payments made under such contracts to petitioner and by him paid over to his wife under prior assignments to her of "all of the income and profits accruing and to accrue to him" under such contracts, are taxable to petitioner, notwithstanding such assignments. Petitioner remained the owner of substantially all the stock of the corporation, and the payments…
1Opinion of the Court
OPINION.
Black, Judge:
The Commissioner in his determination of the deficiencies added to petitioner’s net income for each of the fiscal years before us certain income which he designated “Income with respect to Huth and Reineking contracts.” As a matter of fact the assignment to Louise Mattox of the income and profits from the Reineking contract was not executed by petitioner until February 21, 1940. Only a small amount of the income and profits involved in this proceeding was paid over to Louise Mattox under this latter assignment and it was paid during the fiscal year ending June 30, 1940.…
2Cases cited6 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Helvering v. EubankSupreme Court of the United States · 1941
- Hyman v. CommissionerUnited States Tax Court · 1943
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Mattox v. CommissionerUnited States Tax Court · 1943