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LINDSTROM v. COMMISSIONER

Docket Nos. 188, 189.

3 T.C. 686 (1944)

RALPH G. LINDSTROM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. KATHERINE LINDSTROM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 27, 1944.

Attorney(s) appearing for the Case

Ralph G. Lindstrom, Esq., for the petitioners.

Byron M. Coon, Esq., for the respondent.

These consolidated proceedings involve income tax deficiencies for 1940 as follows: Ralph G. Lindstrom, $347.89; Katherine Lindstrom, $325.52. The issue is whether petitioners are entitled to the benefits of section 107 of the Internal Revenue Code with respect to legal fees received by Ralph G. Lindstrom in 1940 as compensation for services rendered over a period of years.

FINDINGS OF FACT.

Petitioners, husband and wife, reside in Beverly Hills, California...

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