 | United States. Supreme Court - 1932 - 720 sider
...income of the company in 1917, when it first became entitled to them and when it actually received them. If a taxpayer receives earnings under a claim of right...be adjudged liable to restore its equivalent. See Board v. Commissioner, 51 F. (2d) 73, 75, 76. Compare United States v. SS White Dental Mfg. Co., 274... | |
 | United States. Supreme Court - 1932 - 762 sider
...income of the company in 1917, when it first became entitled to them and when it actually received them. If a taxpayer receives earnings under a claim of right...be adjudged liable to restore its equivalent. See Board v. Commissioner, 51 F. (2d) 73, 75, 76. Compare United States v. SS White Dental Mfg. Co., 274... | |
 | United States. Board of Tax Appeals - 1935 - 1394 sider
...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 - 1936 - 1470 sider
...in which it actually received the proceeds from the operation of the property. It was stated that " If a taxpayer receives earnings under a claim of right...still be adjudged liable to restore its equivalent." Seasoning from the language of the Court in that case, the prevailing opinion ha? In my opinion the... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1937 - 144 sider
...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 - 1937 - 1380 sider
...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 - 1942 - 1324 sider
...under a claim of right and without restriction as to its disposition, he has received income which lie is required to return, even though it may still be...adjudged liable to restore its equivalent. » * * See also Cleveland Railway Co. v. Commissioner, 36 Fed. (2cl) 347; certiorari denied, 281 US 743 ; Co-operative... | |
 | Congress. Internal Revenue Taxation Joint Committee - 1953
...The usual statement of the rule is that by Mr. Justice Brandeis in the North American Oil opinion : "If a taxpayer receives earnings under a claim of...still be adjudged liable to restore its equivalent." 286 US, at 424. [282] The phrase "claim of right" is a term known of old to lawyers. Its typical use... | |
 | United States. Tax Court - 1957 - 1440 sider
...Burnet, 286 US 417, the Supreme Court explained the doctrine which we believe is applicable here: It a taxpayer receives earnings under a claim of right...claimed that he is not entitled to retain the money, nnd even though he may still be adjudged liable to restore its equivalent. * * * as to the disposition... | |
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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... 
