The Commissioner determined a deficiency in the income tax liability of Marion B. Pierce, deceased, for 1945, in the amount of $12,855.03. Part of the deficiency is uncontested. There are two questions for decision which arise under section 107(a), as amended, of the 1939 Code: (1) Whether services of Pierce as general counsel of Missouri Pacific Railroad Company, a corporation in reorganization under section 77 of the Bankruptcy Act, were separate from his services as an...
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