Carter v. Commissioner
United States Tax Court
1. Petitioner, a resident of California and an employee of Shell Company, became a member, in 1915, of an employees' fund. Under the plan of the fund, an employee deposited annually a percentage of his salary and Shell deposited a similar or greater amount. The deposits by the employee and by Shell were carried by the fund in the name of the employee, but the account was segregated into two parts.
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1. Petitioner, a resident of California and an employee of Shell Company, became a member, in 1915, of an employees' fund. Under the plan of the fund, an employee deposited annually a percentage of his salary and Shell deposited a similar or greater amount. The deposits by the employee and by Shell were carried by the fund in the name of the employee, but the account was segregated into two parts. The earnings on the segregated deposits were regularly credited to the proper parts. The credit of the deposits made by Shell and the earnings thereon were conditional until the employee had…
1Opinion of the Court
Jean Laing Carter, Petitioner, v. Commissioner of Internal Revenue, Respondent. L. L. Carter, Petitioner, v. Commissioner of Internal Revenue, Respondent
Carter v. Commissioner
Docket Nos. 27918, 27919
United States Tax Court
17 T.C. 994; 1951 U.S. Tax Ct. LEXIS 16;
December 13, 1951, Promulgated
Decisions will be entered under Rule 50.
1. Petitioner, a resident of California and an employee of Shell Company, became a member, in 1915, of an employees' fund. Under the plan of the fund, an employee deposited annually a percentage of his salary and Shell deposited a similar or greater amount. The…
2Cases cited4 opinions
- Sproull v. CommissionerUnited States Tax Court · 1951
- Rogan v. DelaneyCourt of Appeals for the Ninth Circuit · 1940
- Devlin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1936
- Carter v. CommissionerUnited States Tax Court · 1951