Anne K. Heublein and Gilbert W. Heublein v. Commissioner of Internal Revenue

The taxpayer, Gilbert W. Heublein, is a doctor who during 1950 and 1951 employed two other doctors in his practice. The employment contract provided that, in addition to the salaries paid by the taxpayer to the employees, he would accrue in their favor certain percentages of the income from the practice. At the termination of the period of the contract the employee doctors were to have the option to enter into a partnership with the taxpayer. If they entered into such a partnership, the amounts accrued in their favor were to be credited against the purchase of an interest in the taxpayer’s…