Ansorge v. Commissioner
United States Tax Court
An attorney received a power of attorney providing for a fee for his services of 40 percent of any recovery made upon his client's claim for compensation because of expropriation of certain ships and ship contracts by the United States Shipping Board Emergency Fleet Corporation. The power of attorney assigned such 40 percent interest, in any recovery, as fee, to the petitioner. Recovery was made in the Court of Claims, and paid by the United States.
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An attorney received a power of attorney providing for a fee for his services of 40 percent of any recovery made upon his client's claim for compensation because of expropriation of certain ships and ship contracts by the United States Shipping Board Emergency Fleet Corporation. The power of attorney assigned such 40 percent interest, in any recovery, as fee, to the petitioner. Recovery was made in the Court of Claims, and paid by the United States. Held, that the attorney's fee is taxable as ordinary income, and not as capital gain upon a capital asset assigned.
1Opinion of the Court
Martin Charles Ansorge, Petitioner, v. Commissioner of Internal Revenue, Respondent
Ansorge v. Commissioner
Docket No. 109911
United States Tax Court
1 T.C. 1160; 1943 U.S. Tax Ct. LEXIS 158;
May 26, 1943, Promulgated
Decision will be entered under Rule 50.
An attorney received a power of attorney providing for a fee for his services of 40 percent of any recovery made upon his client's claim for compensation because of expropriation of certain ships and ship contracts by the United States Shipping Board Emergency Fleet Corporation. The power of attorney assigned such 40 percent interest, in any…
2Cases cited2 opinions
- Lopez v. United StatesUnited States Court of Claims · 1889
- Ansorge v. CommissionerUnited States Tax Court · 1943