Slough v. Commissioner
United States Tax Court
Petitioners, members of a patent law partnership, performed services continuously over a period in excess of five calendar years.
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Petitioners, members of a patent law partnership, performed services continuously over a period in excess of five calendar years. The firm was paid a total fee of $ 20,875, of which $ 11,500 was received after completion of the services in the taxable year 1940 and the balance of $ 9,375 was received in January 1941. Held, petitioners are not entitled to the benefits of section 107, I. R. C., added by section 220 of the Revenue Act of 1939, since the proportion of the compensation received by petitioners on the completion of their services and required to be returned for Federal income tax…
1Opinion of the Court
OPINION.
Leech, Judge:
These consolidated proceedings involve income tax deficiencies for the calendar year 1940. In Docket No. 2562 respondent determined a deficiency of $1,201.82 against petitioners Frank M. Slough and Josephine C. Slough, husband and wife. Docket No. 2563 involves a deficiency against J. Helen Slough Juergens in the amount of $138.07.
The sole issue is whether the respective petitioners are entitled to the benefits of section 107 of the Internal Revenue Code. The facts were stipulated and are so found.
The petitioners are individuals residing in Cleveland, Ohio. Their returns…
2Cases cited3 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Keeble v. CommissionerUnited States Tax Court · 1943
- Clark v. CommissionerUnited States Tax Court · 1943
3Cited by11 opinions
- Lindstrom v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Ranz v. CommissionerUnited States Tax Court · 1958
- Lindstrom v. CommissionerUnited States Tax Court · 1944
- Smart v. CommissionerUnited States Tax Court · 1945
- Bergh v. PedrickDistrict Court, S.D. New York · 1947
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