WHITMAN
v.
COMMISSIONER OF INTERNAL REVENUE
She originally owned all the 2000 shares, but had given each of her three daughters 25 shares, retaining 1925.
. We need not consider the findings and conclusions of the Tax Court that, in any event, the taxpayer did not receive at least 80% of the total compensation in 3,943.
. That section reads: “If at least 80 per centum of the total compensation for personal services covering a period of thirty-six calendar months or more (from the beginning to the completion of such services) is received or accrued in one taxable year by an individual or a partnership, the tax attributable to any part thereof which is included in the gross income of any individual shall not be greater than the aggregate of the taxes attributable to such part had it been included in the gross income of such individual ratably over that part of the period which precedes the date of such receipt or accrual.”