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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... "
Reports of the Tax Court of the United States - Page 468
by United States. Tax Court - 1959
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Cases Decided in the Court of Claims of the United States, Volume 93

United States. Court of Claims - 1941 - 858 pages
...from gross income in 1931. In North American Oil v. Burnet, 286 US 417, 424, the Supreme Court said: If a taxpayer receives earnings under a claim of right...still be adjudged liable to restore its equivalent [citing other authorities]. The rule laid down above has been followed in other cases and repeated...
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Cases Decided in the United States Court of Claims ... with ..., Volume 149

United States. Court of Claims, Audrey Bernhardt - 1962 - 964 pages
...language found in North American Oil v. Bumet, 286 US 417, 424 (1932), where the Supreme Court said : If a taxpayer receives earnings under a claim of right...has received income which he is required to return [for tax purposes], even though it may still be claimed that he is not entitled to retain the money,...
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Cases Decided in the Court of Claims of the United States, Volume 109

United States. Court of Claims - 1948 - 974 pages
...1942. As we have said, the Government demurs. It says that the plaintiff received the $24,000 in 1942 under a claim of right, and without restriction as to its disposition, and that that ends the controversy. It points to North American OH Consolidated v. Butrnet, 286 US...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 286

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1932 - 720 pages
...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...still 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.,...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 286

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1932 - 762 pages
...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...still 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.,...
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Reports of the U.S. Board of Tax Appeals, Volume 31

United States. Board of Tax Appeals - 1935 - 1394 pages
...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...
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Reports of the U.S. Board of Tax Appeals, Volume 33

United States. Board of Tax Appeals - 1936 - 1468 pages
...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...
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The Taxing Power of the Federal and State Governments: Report ..., Volumes 8-11

United States. Congress. Joint Committee on Internal Revenue Taxation - 1937 - 144 pages
...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...
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Reports of the U.S. Board of Tax Appeals, Volume 35

United States. Board of Tax Appeals - 1937 - 1380 pages
...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...
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Cases Decided in the Court of Claims of the United States, Volume 85

United States. Court of Claims - 1938 - 764 pages
...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...to retain the money, and even though he may still l>e adjudged liable to restore its equivalent. See* Board v. Commissioner, 51 F. (2d) 73. 75, 76. Compare...
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