Legal Opinion

Allen v. Commissioner

United States Tax Court

Decided December 12, 1945No. Docket No. 1223Published

Petitioner Leland J. Allen, an attorney, conducted litigation under a contingent fee agreement made in 1933 whereby, if successful in establishing his client's right to an oil royalty interest, petitioner was to receive one-half of his client's interest in the lease and one-half of any accumulations thereon during the pendency of the controversy.

Read the full summary

Petitioner Leland J. Allen, an attorney, conducted litigation under a contingent fee agreement made in 1933 whereby, if successful in establishing his client's right to an oil royalty interest, petitioner was to receive one-half of his client's interest in the lease and one-half of any accumulations thereon during the pendency of the controversy. On the facts, held, (1) petitioner was entitled to receive his interest in the lease and accumulations upon completion of his contract and not before; (2) Commissioner's determination that petitioner's interest in the lease had a value of $ 3,483.90…

1Opinion of the Court

Leland J. Allen and Lucy A. Allen, Petitioners, v. Commissioner of Internal Revenue, Respondent

Allen v. Commissioner

Docket No. 1223

United States Tax Court

5 T.C. 1232; 1945 U.S. Tax Ct. LEXIS 24;

December 12, 1945, Promulgated

Decision will be entered under Rule 50.

Petitioner Leland J. Allen, an attorney, conducted litigation under a contingent fee agreement made in 1933 whereby, if successful in establishing his client's right to an oil royalty interest, petitioner was to receive one-half of his client's interest in the lease and one-half of any accumulations thereon during the pendency of the…

2Cases cited8 opinions

  1. Cantwell v. ConnecticutSupreme Court of the United States · 1940
  2. Sutphin v. SpeikCalifornia Supreme Court · 1940
  3. Helvering v. O'DONNELLSupreme Court of the United States · 1938
  4. Bartlett v. Odd FelLows' Savings BankCalifornia Supreme Court · 1889
  5. Hoffman v. VallejoCalifornia Supreme Court · 1873

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API