Worm v. Commissioner

WILKERSON, District Judge.

Section 213 of tho Revenue Act of 1921, e. 136, 42 Stat. 227, 238, requires that for income tax purposes there shall be included “gains, profits, and income derived- from * * * compensation for personal service * * * or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; * * * or gains or profits and income derived from any source whatever.”

That section also requires that the amount of such items, except as otherwise provided, shall be included in the gross income for the taxable year in which…