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KAMPEL v. C. I. R.

Docket No. 80-4020.

634 F.2d 708 (1980)

Daniel S. KAMPEL and Clarisse Kampel, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided November 25, 1980.

Attorney(s) appearing for the Case

Eugene L. Vogel, New York City (Marc E. Nitsche and Rosenman, Colin, Freund, Lewis & Cohen, New York City, on the brief), for petitioners-appellants.

James A. Riedy, Atty., Tax Division, Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews and David English Carmack, Attys., Tax Division, Dept. of Justice, Washington, D. C., on the brief), for respondent-appellee.

Before LUMBARD, OAKES and NEWMAN, Circuit Judges.

NEWMAN, Circuit Judge:

This appeal involves the narrow question whether guaranteed partnership income, viewed as salary by Internal Revenue Code § 707(c), is subject to the limits on taxation of earned income imposed by Code§1348, for tax years prior to 1978.1 The taxpayer-appellant treated all of his§707(c) payments as earned income in order to receive the more favorable 50% maximum tax rate of § 1348. However, under...

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