Fred C. Hall v. Commissioner of Internal Revenue

Ninth Circuit

Fred C. Hall v. Commissioner of Internal Revenue

194 F.2d 538

Court of Appeals for the Ninth Circuit·Decided May 6, 1952·No. 12803_1·Published·Cited by 2 cases

Opinion

PER CURIAM.

The petitioner, taxpayer, is here seeking review of a Tax Court decision which was adverse to him. The Tax Court determined that the taxpayer is taxable in 1943 and 1944 rather than in 1942 on the value of corporate stock involved in a written contract whereby petitioner was employed by the corporation. We do not. find that there was clear error in the Tax Court’s Findings of Fact and Opinion as reported in 15 T.C. 195. However, we withhold approval of the Tax Court’s comment in reference to payment for corporate stock under Ohio laws. The point was not before the court.

Affirmed.

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PER CURIAM.

The petitioner, taxpayer, is here seeking review of a Tax Court decision which was adverse to him. The Tax Court determined that the taxpayer is taxable in 1943 and 1944 rather than in 1942 on the value of corporate stock involved in a written contract whereby petitioner was employed by the corporation. We do not. find that there was clear error in the Tax Court’s Findings of Fact and Opinion as reported in 15 T.C. 195. However, we withhold approval of the Tax Court’s comment in reference to payment for corporate stock under Ohio laws. The point was not before the court.

Affirmed.

Fred C. Hall v. Commissioner of Internal Revenue, 194 F.2d 538 (9th Cir. 1952).

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Opinion

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