Lehman v. Commissioner
United States Tax Court
1. Income -- Deduction -- Alimony Payments -- Sections 23 (u), 22 (k). -- Payments made by a divorced husband to the mother of his former wife, "for and in behalf of" the wife who was the sole support of her mother are deductible under section 23 (u). 2. Income -- Realization -- Stock for Services -- Termination of Restrictions. -- The termination of restrictions on stock, having no fair market value when previously received for services, was not an event giving rise to…
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1. Income -- Deduction -- Alimony Payments -- Sections 23 (u), 22 (k). -- Payments made by a divorced husband to the mother of his former wife, "for and in behalf of" the wife who was the sole support of her mother are deductible under section 23 (u). 2. Income -- Realization -- Stock for Services -- Termination of Restrictions. -- The termination of restrictions on stock, having no fair market value when previously received for services, was not an event giving rise to income for tax purposes.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $6,018.20 for 1944. The issues for decision are whether an annual payment of $5,000 to the mother of the petitioner’s divorced wife is deductible under section 23 (u) and whether a partnership in which the petitioner had an interest realized ordinary income on January 1, 1944, when some restrictions terminated on stock theretofore received by the partnership. The parties filed a stipulation of facts which is adopted as the findings of fact.
The petitioner filed his individual return for 1944 with the collector of internal…
2Cases cited2 opinions
- Stewart v. CommissionerUnited States Tax Court · 1947
- Hart v. CommissionerUnited States Tax Court · 1948
3Cited by46 opinions
- Wright v. CommissionerUnited States Tax Court · 1974
- Glen v. CommissionerUnited States Tax Court · 1966
- Husted v. CommissionerUnited States Tax Court · 1967
- Sakol v. CommissionerUnited States Tax Court · 1977
- Katharine T. Hyde v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
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