Legal Opinion

Findlay v. Commissioner

United States Tax Court

Decided December 27, 1962No. Docket Nos. 80418, 87262Published

Decedent, who had solicited insurance for a British firm on a commission basis, executed an agreement in 1936 providing for the payment of commissions after his death in designated amounts and for a limited period.

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Decedent, who had solicited insurance for a British firm on a commission basis, executed an agreement in 1936 providing for the payment of commissions after his death in designated amounts and for a limited period. He bequeathed one-half of the commission payments to petitioner, who was divorced from decedent in 1948. Decedent died in 1951, and petitioner agreed in 1952 and 1953 to accept $ 150,000 in full settlement of her claim, and also agreed to a reduction in her payments for a portion of amounts required to pay British death duty. Petitioner received $ 50,000 from the British insurance…

1Opinion of the Court

Helen Rich Findlay, Petitioner, v. Commissioner of Internal Revenue, Respondent

Findlay v. Commissioner

Docket Nos. 80418, 87262

United States Tax Court

39 T.C. 580; 1962 U.S. Tax Ct. LEXIS 5;

December 27, 1962, Filed

Decisions will be entered for the respondent.

Decedent, who had solicited insurance for a British firm on a commission basis, executed an agreement in 1936 providing for the payment of commissions after his death in designated amounts and for a limited period. He bequeathed one-half of the commission payments to petitioner, who was divorced from decedent in 1948. Decedent died in 1951,…

2Cases cited19 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Auerbach Shoe Co. v. CommissionerUnited States Tax Court · 1953
  3. Auerbach Shoe Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1954
  4. Joyce v. GentschCourt of Appeals for the Sixth Circuit · 1944
  5. Silverman v. CommissionerUnited States Tax Court · 1957

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