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MYERS v. COMMISSIONER

Docket Nos. 914, 3216.

11 T.C. 447 (1948)

GUY C. MYERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 28, 1948.

Attorney(s) appearing for the Case

George R. Sheriff, Esq., and George V. Mahoney, Esq., for the petitioner.

Wilford H. Payne, Esq., Douglas Barnes, Esq., John T. Rogers, Esq., and Kennedy C. Watkins, Esq., for the respondent.

HARLAN, Judge:

The Commissioner determined deficiencies in Federal income tax for the years 1940 and 1941 in the respective amounts of $123,209.49 and $223,662.30. Three questions are presented:

(1) Whether the income received by the petitioner during the taxable years 1940 and 1941 under contracts with various public utility districts is subject to taxation under the limitations provided by section 107 of the Internal Revenue Code.

(2) Whether...

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