Estate of French v. Glander

The single question presented is whether the amounts paid to the taxpayer, Professor French, in the year 1942, under his contracts with McGraw-Hill Book Company, are exempt from taxation as salary or wages under a contract of employment. The appellant contends that the contracts are contracts of employment, and that the payments made thereunder constituted salary or wages and therefore are exempt from taxation. The appellee contends that the amounts were paid upon an investment, to wit, the right to receive a royalty, a form of intangible personal property.

The provisions of the Constitution…