Veit v. Commissioner

The United States Tax Court decided two cases, both titled Veit v. Commissioner, in 1947 and 1949.

[1] In Veit I, the first of the two cases, the IRS objected to the new contract, claiming that the bonus from the 1940 profits was constructively received in 1941 and thus should have been included as part of the taxpayer's gross income for 1941, rather than 1942.

[1] The Tax Court disagreed, finding that the November 1940 agreement was "an arm's length business transaction .

[1] At issue in Veit II was a further agreement, entered into in December 1941, allowing the 1940 bonus to be paid in five equal installments annually from 1942 to 1946, instead of the entire amount in 1942.

[2] The deferral was at the request of the corporation, and the full amount of the bonus was never "unqualifiedly subject to [the taxpayer's] demand or withdrawal.