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KAZAN v. COMMISSIONER

Docket No. 60371.

16 T.C.M. 196 (1957)

T.C. Memo. 1957-44

Abraham E. Kazan and Freda Kazan v. Commissioner.

United States Tax Court.

Filed March 15, 1957.

Attorney(s) appearing for the Case

Phillip I. Blumberg, Esq., for the petitioners. William F. Chapman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in petitioners' income taxes for 1951 in the amount of $3,474.89.

The only issue for decision is whether a payment of $25,000 to petitioner Abraham E. Kazan in 1951 represented at least 80 per cent of the total compensation for personal services covering a period of 36 months or more within the meaning of section 107(a) of the Internal Revenue Code of 1939.

Findings...

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