BENNETT v. COMMISSIONER

Docket No. 38197.

23 T.C. 1073 (1955)

COMPTON BENNETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 29, 1955.


Attorney(s) appearing for the Case

J. Everett Blum, Esq., for the petitioner.

George E. Constable, Esq., for the respondent.


The Commissioner determined a deficiency in the income tax of the petitioner for the year 1948 in the amount of $26,773.79. Petitioner claims an overpayment in the amount of $11,277.22. The sole issue is whether the full amount of $122,333.33 received by petitioner in 1948 under a contract for the performance of services for Metro-Goldwyn-Mayer Pictures constituted gross income to him in that year or whether a portion of that amount, namely $38,034.49, must be excluded from...

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