Legal Opinion

Abramo v. Commissioner

United States Tax Court

Decided January 29, 1982No. Docket No. 4666-79, 4708-79Published

Held: Amounts specifically designated in a separation agreement as payable for child support were "fixed" within the meaning of sec. 71(b), I.R.C. 1954, even though the designation was prefaced by the phrase "for tax purposes." Accordingly, amounts paid pursuant to the agreement were neither deductible by H nor includable in W's gross income.

1Opinion of the Court

Arnold A. Abramo and Mary J. Abramo, Petitioners v. Commissioner of Internal Revenue, Respondent; Mary Louise Abramo, Petitioner v. Commissioner of Internal Revenue, Respondent

Abramo v. Commissioner

Docket No. 4666-79, 4708-79

United States Tax Court

78 T.C. 154; 1982 U.S. Tax Ct. LEXIS 141; 78 T.C. No. 11;

January 29, 1982, Filed

Decisions will be entered under Rule 155.

Held: Amounts specifically designated in a separation agreement as payable for child support were "fixed" within the meaning of sec. 71(b), I.R.C. 1954, even though the designation was prefaced by the phrase "for tax purposes."…

Also in this document: Dissent.

2Cases cited23 opinions

  1. Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. First Nat. Bank of Ariz. v. Cities Service Co.Supreme Court of the United States · 1968
  4. Corliss v. BowersSupreme Court of the United States · 1930
  5. Commissioner v. LesterSupreme Court of the United States · 1961

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