Legal Opinion
Roy I. Martin and Elizabeth E. Martin v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 28, 1962No. 13759PublishedCited by 13 opinions
1Opinion of the Court
• STALEY, Circuit Judge.
This appeal involves the taxability of money paid by a corporation to the widow of one of its officers. At his death, Arthur Purdy was president of A. R. Purdy Co., Inc. (“corporation”). Pursuant to a resolution passed by its board of directors, the corporation paid decedent’s widow, petitioner, 1 $32,727.24 in 1955 and $27,272.76 in 1956. Petitioner failed to report these payments as income on her tax returns, causing the Commissioner to assess a deficiency against her on the basis that they were subject to treatment as ordinary income. The Tax Court upheld the…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- United States v. KaiserSupreme Court of the United States · 1960
- Mildred W. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Martin v. CommissionerUnited States Tax Court · 1961
3Cited by13 opinions
- Eva L. Gaugler, on Behalf of Herself and as Under the Last Will and Testament of Raymond C. Gaugler, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1963
- Findlay v. CommissionerUnited States Tax Court · 1962
- Evans v. CommissionerUnited States Tax Court · 1962
- United States v. Mabel Carroll Pixton, IndividuallyCourt of Appeals for the Fifth Circuit · 1964
- Bank of Palm Beach & Trust Co. v. United StatesUnited States Court of Claims · 1973
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