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WATTLEY v. COMMISSIONER

Docket No. 62297.

20 T.C.M. 111 (1961)

T.C. Memo. 1961-24

Ralph B. Wattley and Josephine R. Wattley v. Commissioner.

United States Tax Court.

Filed January 31, 1961.

Attorney(s) appearing for the Case

Ralph B. Wattley, pro se, 141-48 85th Road, Kew Gardens, New York, N. Y. Clarence P. Brazill, Jr., Esq., for the respondent.

Memorandum Opinion

RAUM, Judge:

This case is here on remand from the Court of Appeals for the Second Circuit (275 F.2d 461), which reviewed our prior decision herein (31 T.C. 510). The issue was whether the taxpayer was entitled to spread a commission of $30,666.67, received early in 1951, over a period of some 19 years pursuant to Section 107(a) of the Internal Revenue Code of 1939. The question...

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