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SPEARS v. COMMISSIONER

Docket No. 6823.

7 T.C. 1271 (1946)

J. MACKAY SPEARS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 4, 1946.

Attorney(s) appearing for the Case

Prew Savoy, Esq., for the petitioner.

Elmer L. Corbin, Esq., for the respondent.

The petitioner received $30,000 in 1941 as part of his compensation for personal services performed over a period of years. He computed his income tax for 1941 by applying the provisions of section 107 of the Internal Revenue Code. The respondent determined that section 107 was not applicable and that there was a deficiency of $13,537.47. Petitioner alleges that respondent erred in this. In an amended petition an overpayment of $157...

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