HALL v. COMMISSIONER OF INTERNAL REVENUE

No. 4121.

89 F.2d 441 (1937)

HALL v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

April 6, 1937.


Attorney(s) appearing for the Case

William D. Whitney, of New York City (Richard H. Wilmer, of Washington, D. C., and George G. Tyler and Cravath, DeGersdorff, Swaine & Wood, all of New York City, on the brief), for petitioner.

John J. Pringle, Jr., Sp. Asst. to Atty. Gen. (Robert H. Jackson, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.


PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals; and the question involved is whether a payment of $50,000 made to taxpayer was a gift or additional compensation for services rendered. Taxpayer is a patent attorney who over a period of years had rendered services to the Universal Oil Products Company, a corporation whose chief property consisted of certain patents and patent rights. In 1931 the stockholders of that corporation...

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