Question juridique clé
Whether income for the surtax calculation may be taken into account in the year of actual payment, even if it relates to earlier years.
Solution extraite
Yes. The office could validly use the income in the year it was actually paid, including salary elements attributable to prior years, because those elements had not previously been taken into account.
Motifs extraits
The court accepted the office's method of allocation to the year of payment. Since the earlier salary elements had not been considered in previous periods, their inclusion in the surtax base when paid was permissible.