The Commissioner determined a deficiency of $888.57 in petitioner's income tax for the calendar year 1939, all of which is here in issue. The deficiency arises by reason of respondent's determination (1) that a fee earned by petitioner as an attorney for work beginning May 16, 1934, and ending May 22, 1939, and paid in full on May 22, 1939, was not taxable pursuant to section 107, Internal Revenue Code, but was includible in full in petitioner's taxable income for 1939, ...
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