 | United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - Law reports, digests, etc - 1932 - 762 pages
...Syllabus. 286 US account of income which it had not yet received and which it might never receive. Third. The net profits earned by the property in 1916 were...to retain the money, and even though he may still be adjudged liable to restore its equivalent. See Board v. Commissioner, 51 F. (2d) 73, 75, 76. Compare... | |
 | United States. Supreme Court - Law reports, digests, etc - 1932 - 720 pages
...receive. Third. The net profits earned by the property in 1916 were not income of the year 1922—the year in which the litigation with the Government was...to retain the money, and even though he may still be adjudged liable to restore its equivalent. See Board v. Commissioner, 51 F. (2d) 73, 75, 76. Compare... | |
 | United States. Board of Tax Appeals - Taxation - 1935 - 1394 pages
...The Supreme Court in the North American Oil Consolidated case, laid down the rule as follows: * * * If a taxpayer receives earnings under a claim of right...received income which he is required to return, even thougli it may still be claimed that he is not entitled to retain the money, and even though he may... | |
 | United States. Board of Tax Appeals - Taxation - 1936 - 1468 pages
...taxable in 1916 on account of income which it had not yet received and which it might never receive. became entitled to them and when it actually received...to retain the money, and even though he may still be adjudged liable to restore its equivalent. See Board v. Commissioner of Internal Revenue (0. CA),... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - Taxation - 1937 - 144 pages
...When it is that, it may be taxed, though it was in the making long before (citations omitted). But if a taxpayer receives earnings under a claim of right...restriction as to its disposition, he has received income, even though he may still be held liable to restore its equivalent.125" * From the foregoing it is clear... | |
 | United States. Board of Tax Appeals - Taxation - 1937 - 1380 pages
...contentions and not those of the respondent. In the course of its opinion the Court stated : * * * If a taxpayer receives earnings under a claim of right...he is required to return, even though it may still he claimed that he Is not entitled to retain the money, and even though he may still be adjudged liable... | |
 | United States. Board of Tax Appeals - Taxation - 1942 - 1324 pages
...189. In North American Oil Consolidated v. Burnet, 286 US 417, the Court stated as follows : • • * If a taxpayer receives earnings under a claim of right...as to its disposition, he has received income which lie is required to return, even though it may still be claimed that he is not entitled to retain the... | |
 | United States. Congress. House. Committee on Ways and Means - Income tax - 1955 - 320 pages
...evident in the claim-of -right cases. The Supreme Court stated the claim-of-right doctrine as follows : M "If a taxpayer receives earnings under a claim of...has received income which he is required to return (for tax purposes) even though it may still be claimed that he is not entitled to retain the money,... | |
 | United States. Congress. House. Committee on Ways and Means - Income tax - 1955 - 364 pages
...evident in the claim-of -right cases. The Supreme Court stated the elaim-of-right doctrine as follows : w "If a taxpayer receives earnings under a claim of...has received income which he is required to return (for tax purposes) even though it may still be claimed that he is not entitled to retain the money,... | |
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If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though... 
