 | United States. Supreme Court - 1932 - 720 pages
...it first became entitled to them and when it actually received them. 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... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1937 - 144 pages
...taxed, though it was in the making long before (citations omitted). But if a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income, even though he may still be held liable to restore its equivalent.125" * From... | |
 | Congress. Internal Revenue Taxation Joint Committee - 1953
...is that by Mr. Justice Brandeis in the North American Oil opinion : "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... | |
 | United States. Congress. House. Committee on Ways and Means - 1955 - 364 pages
...The Supreme Court stated the elaim-of-right doctrine as follows : w "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 (for tax purposes) even though it may still be... | |
 | United States. Congress. House. Committee on Ways and Means - 1955 - 320 pages
...The Supreme Court stated the claim-of-right doctrine as follows : M "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 (for tax purposes) even though it may still be... | |
 | United States. Tax Court - 1959 - 1372 pages
...Brandéis in North American Oil Consolidated v. Burnet, 286 US 417,424: 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... | |
 | United States. Supreme Court - 1969 - 1102 pages
...See GCM 16730, XV-1 Cum. Bull. 179, 181 (1936): "In the instant case the taxpayer received the income under a claim of right and without restriction as to its disposition. On authority of the cases cited herein, this office is of the opinion that the profits in question... | |
 | United States. Internal Revenue Service - 1975 - 652 pages
...the personal property subsequent to the date of A's death. Further, if a taxpayer receives earnings under a claim of right and without restriction as to its disposition, the taxpayer has received income, even though there is a claim that the taxpayer is not entitled to... | |
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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... 
