Anderson v. Commissioner

First Circuit

Anderson v. Commissioner

137 F. App'x 373

CourtCourt of Appeals for the First Circuit

DecidedJuly 5, 2005

Docket04-2628

StatusPublished

Cited by1 cases

This text of 137 F. App'x 373 (Anderson v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Anderson v. Commissioner, 137 F. App'x 373 (1st Cir. 2005).

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Opinion

PER CURIAM.

After carefully considering the briefs and record on appeal, we affirm for substantially the reasons stated by the Tax Court. 1 Among other problems, the appellants fail to show that the statute categorizes their income as employee income. ‘Proceeds’ is not synonymous with ‘gross proceeds’. The amount of compensation paid to one entitled to receive only a share of the net proceeds from the sale of the catch depends on the size of the catch, as required.

The appellants have not presented a coherent account of their interpretation of the regulation. The amount of a share of the catch, in their sense, must always depend on many factors other than catch-size, e.g., the market and other conditions.

Affirmed. 1st Cir. R. 27(c).

1

. Accordingly, we deny oral argument.

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PER CURIAM.

After carefully considering the briefs and record on appeal, we affirm for substantially the reasons stated by the Tax Court. 1 Among other problems, the appellants fail to show that the statute categorizes their income as employee income. ‘Proceeds’ is not synonymous with ‘gross proceeds’. The amount of compensation paid to one entitled to receive only a share of the net proceeds from the sale of the catch depends on the size of the catch, as required.

The appellants have not presented a coherent account of their interpretation of the regulation. The amount of a share of the catch, in their sense, must always depend on many factors other than catch-size, e.g., the market and other conditions.

Affirmed. 1st Cir. R. 27(c).

1

. Accordingly, we deny oral argument.

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Bluebook (online)

137 F. App'x 373, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-commissioner-ca1-2005.

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