MARSHALL v. COMMISSIONER

Docket Nos. 23432, 23433.

14 T.C. 90 (1950)

ELDER W. MARSHALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ELDER W. MARSHALL AND BESSIE I. MARSHALL, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 27, 1950.


Attorney(s) appearing for the Case

Sidney B. Gambill, Esq., and Norman D. Keller, Esq., for the petitioners.

Albert J. O'Connor, Esq., for the respondent.


OPINION.

OPPER, Judge:

The deficiencies in issue are for income tax in the respective amounts of $5,388.96 for the year 1943 in Docket No. 23432 and $3,001.64 for the year 1945 in Docket No. 23433. Petitioner claims an overpayment. The issue in each of the consolidated proceedings is whether petitioner, as a member of a law partnership, is entitled to apply section 107, Internal Revenue Code, so as to include in the time of the rendition of the services...

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