Legal Opinion

Wright v. Commissioner

United States Tax Court

Decided May 29, 1958No. Docket No. 59143PublishedCited by 4 opinions

Petitioner represented a Japanese alien, Fujii, in a case to test the constitutionality of the California alien land acts. After lengthy litigation the acts were declared unconstitutional by the California Supreme Court.

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Petitioner represented a Japanese alien, Fujii, in a case to test the constitutionality of the California alien land acts. After lengthy litigation the acts were declared unconstitutional by the California Supreme Court. The Japanese in California were pleased that the alien land acts had been declared unconstitutional, and a committee was formed under the auspices of the Japanese Chamber of Commerce of Southern California to collect a fund to be given to petitioner and Fujii as a token of appreciation and gratitude. Nearly 1,100 individuals contributed to the fund. A dinner was held in honor…

1Opinion of the Court

Beuce, Judge:

This proceeding involves a deficiency of $4,586.80 in income tax for the calendar year 1952. The sole issue is whether $10,000 presented to petitioner by the Japanese Chamber of Commerce of Southern California in behalf of the Japanese of California was a gift or compensation for services rendered. Certain concessions were made by petitioner.

FINDINGS OF FACT.

J. Marion Wright (hereinafter referred to as petitioner) and Alice M. Wright are husband and wife and reside in Los Angeles, California. They filed a joint income tax return for the calendar year 1952 with the district…

2Cases cited4 opinions

  1. Bogardus v. CommissionerSupreme Court of the United States · 1937
  2. Sei Fujii v. State of CaliforniaCalifornia Supreme Court · 1952
  3. Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  4. Estate of McAdow v. CommissionerUnited States Tax Court · 1949

3Cited by4 opinions

  1. Kralstein v. CommissionerUnited States Tax Court · 1962
  2. Abdella v. CommissionerUnited States Tax Court · 1983
  3. Kralstein v. CommissionerUnited States Tax Court · 1962
  4. Wright v. CommissionerUnited States Tax Court · 1958

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