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REYNOLDS v. COMMISSIONER OF INTERNAL REVENUE

No. 7490.

249 F.2d 259 (1957)

George E. REYNOLDS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided November 7, 1957.

Attorney(s) appearing for the Case

Andrew D. Sharpe, Washington, D. C. (H. Stewart McDonald, Washington, D. C., on brief), for petitioner.

L. W. Post, Attorney, Department of Justice, Washington, D. C. (John N. Stull, Acting Asst. Atty. Gen., and Lee A. Jackson, Attorney, Department of Justice, Washington, D. C., on brief), for respondent.

Before PARKER, Chief Judge, and SOPER and HAYNSWORTH, Circuit Judges.

SOPER, Circuit Judge.

This petition to review a decision of the Tax Court raises the question whether the taxpayer, who received the sum of $55,536 in 1942 for services rendered over a period of thirty-six months, is entitled, in computing his tax liability for the year, to spread the payment over the period in which the services were rendered under § 107(a) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 107(a).1

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