Legal Opinion
Mason v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 14, 1942No. 8770PublishedCited by 4 opinions
1Opinion of the Court
ALLEN, Circuit Judge.
This is a petition to review the decision of the Board of Tax Appeals involving a deficiency in income tax in the amount of $10,827.57 for the year 1935. The Board sustained the Commissioner. 41 B.T.A. 1287.
The principal question presented is whether, when a taxpayer’s contract of employment provides, in addition to other compensation, for a money bonus, and the taxpayer is required by an inseparable provision of the same contract to exchange the amount of the bonus directly upon its receipt for stock of the company at a fixed value, the taxpayer realizes taxable income…
2Cases cited5 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Omaha Nat. Bank v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
- Old Colony Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1932
- Rodrigues v. EdwardsCourt of Appeals for the Second Circuit · 1930
- Mason v. CommissionerUnited States Board of Tax Appeals · 1940
3Cited by4 opinions
- Connolly's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Frazer v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946
- Smith v. CommissionerCourt of Appeals for the Ninth Circuit · 1944
- Frazer v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946