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WARRICK v. COMMISSIONER

Docket No. 15275.

7 T.C.M. 398 (1948)

Dupuy G. Warrick and Violette G. Warrick, husband and wife v. Commissioner.

United States Tax Court.

Entered June 25, 1948.

Attorney(s) appearing for the Case

Albert F. Hillix, Esq., and John E. Park, Esq., Bryant Bldg., Kansas City, Mo., for the petitioners. Harlow B. King, Esq., and Gene W. Reardon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency in income tax of the petitioners for the year 1940 in the amount of $38,972.03. The sole issue is whether section 107 of the Internal Revenue Code may be applied in computing the petitioners' tax attributable to a fee of $125,000 received by Dupuy G. Warrick in 1940 for legal services.

A stipulation of facts, documentary evidence and oral testimony were submitted, from which we...

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