Legal Opinion

Roubik v. Commissioner

United States Tax Court

Decided December 3, 1969No. Docket Nos. 3095-68, 3105-68, 3106-68, 3107-68PublishedCited by 42 opinions

In 1961 the petitioners, previously engaged separately in their common specialty of radiology, formed a professional service corporation, validly incorporated pursuant to State law. Each entered into an employment agreement with the corporation. Thereafter and during the taxable year in issue each continued to engage separately in his individual practice.

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In 1961 the petitioners, previously engaged separately in their common specialty of radiology, formed a professional service corporation, validly incorporated pursuant to State law. Each entered into an employment agreement with the corporation. Thereafter and during the taxable year in issue each continued to engage separately in his individual practice. During the taxable year involved herein, the corporation was an "electing small business corporation" within the meaning of sec. 1371(b) I.R.C. 1954. The income generated from the services rendered by the petitioners was turned over to the…

1Opinion of the Court

Tietjens, Judge.

The Commissioner determined deficiencies in income taxes of petitioners in these consolidated cases as follows:

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Only the deficiencies determined for 1965 are in dispute. The only issue presented for decision by us for that year is whether certain amounts of income resulting from the performance of professional services by each of the individual petitioners during 1965 were earned by and taxable as income to “Drs. Pfeifer, Ramin, Zautcke & Associates, Chartered,” a professional service corporation, or whether they were earned by and taxable to the individual…

2Cases cited7 opinions

  1. Rubin v. CommissionerUnited States Tax Court · 1968
  2. United States v. Lawrence G. EmpeyCourt of Appeals for the Tenth Circuit · 1969
  3. Commissioner of Internal Revenue v. LaughtonCourt of Appeals for the Ninth Circuit · 1940
  4. Hugh A. O'Neill and Elizabeth O'Neill v. United StatesCourt of Appeals for the Sixth Circuit · 1969
  5. Howard A. Kurzner and C. A. Kurzner v. United StatesCourt of Appeals for the Fifth Circuit · 1969

2 more not listed; retrieve them via the Exa API.

3Cited by42 opinions

  1. Zmuda v. CommissionerUnited States Tax Court · 1982
  2. Achiro v. CommissionerUnited States Tax Court · 1981
  3. Wesenberg v. CommissionerUnited States Tax Court · 1978
  4. Haag v. CommissionerUnited States Tax Court · 1987
  5. American Sav. Bank v. CommissionerUnited States Tax Court · 1971

37 more not listed; retrieve them via the Exa API.

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