SPEARS v. COMMISSIONER OF INTERNAL REVENUE

No. 9430.

164 F.2d 486 (1947)

SPEARS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided November 26, 1947.


Attorney(s) appearing for the Case

Prew Savoy, of Washington, D.C., for petitioner.

Harry Baum, of Washington, D.C. (Theron Lamar Caudle, Asst. Atty. Gen., and Helen R. Carloss and George A. Stinson, Sp. Assts. to Atty. Gen., on the brief) for respondent.

Before MARIS, O'CONNELL, and KALODNER, Circuit Judges.


PER CURIAM.

The question which this case presents is whether the Tax Court erred in determining that the total compensation received by the taxpayer for engineering services performed by him in connection with a series of construction projects for a single employer under a single employment contract must be taken into account in determining whether the taxpayer was entitled to the benefit of Section 107 of the Internal Revenue Code, 26 U.S.C.A.Int.Rev.Code, §...

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