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Veit v. Commissioner

United States Tax Court

8 T.C.M. 919 (1949)

Relevant factsFree

Howard Veit (plaintiff) again deferred payment of his 1940 cotton-goods company bonus, this time renegotiating with the company in December 1941 to spread payment of the 1940 bonus over 1942 through 1946, at the company's own request. The commissioner (defendant) determined Veit constructively received the entire 1940 bonus in 1942 and assessed tax deficiencies accordingly; Veit petitioned the Tax Court for redetermination.

IssueFree

Whether a federal taxpayer constructively receives deferred income if the taxpayer has an unqualified right to demand the money.

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