Pulver v. Commissioner
United States Tax Court
P was employed by GEC as a chief engineer. Additionally, GEC paid P a percentage of the selling price of inventions created by P and marketed by GEC. Held: although P was employed by GEC as a chief engineer he was also a self-employed inventor. Accordingly, contributions made by P to a self-employment retirement plan are deductible and interest earned thereon is nontaxable.
1Opinion of the Court
HARRY E. PULVER AND THELMA J. PULVER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pulver v. Commissioner
Docket No. 4886-79.
United States Tax Court
T.C. Memo 1982-437; 1982 Tax Ct. Memo LEXIS 305; 44 T.C.M. (CCH) 644; T.C.M. (RIA) 82437;
August 2, 1982.
P was employed by GEC as a chief engineer. Additionally, GEC paid P a percentage of the selling price of inventions created by P and marketed by GEC.
Held: although P was employed by GEC as a chief engineer he was also a self-employed inventor. Accordingly, contributions made by P to a self-employment retirement plan are deductible…
2Cases cited8 opinions
- Simpson v. CommissionerUnited States Tax Court · 1975
- Packard v. CommissionerUnited States Tax Court · 1975
- Manouchehr and Lila M. Azad v. United StatesCourt of Appeals for the Eighth Circuit · 1968
- Air Terminal Cab, Inc. v. United States of America, Airway Taxi Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1973
- Chilton v. CommissionerUnited States Tax Court · 1963
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- United States v. Albert IsakssonCourt of Appeals for the Seventh Circuit · 1984