Legal Opinion

Morrow v. Commissioner

United States Tax Court

Decided June 23, 1943No. Docket No. 112203Published

The purchase by petitioner of two annuity contracts providing for the payment of a total of $ 200 per month to an employee being retired after many years of valuable service, rendered with the understanding that retirement would be on a pension, held to be payment of additional compensation for such service and, accordingly, the cost of the annuity feature of each contract is not subject to gift tax.

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The purchase by petitioner of two annuity contracts providing for the payment of a total of $ 200 per month to an employee being retired after many years of valuable service, rendered with the understanding that retirement would be on a pension, held to be payment of additional compensation for such service and, accordingly, the cost of the annuity feature of each contract is not subject to gift tax. Further held that additional amounts paid by petitioner for the inclusion in each annuity contract of a refund provision obligating the insurer, in case of death of the annuitant before the total…

1Opinion of the Court

Elizabeth C. Morrow, Petitioner, v. Commissioner of Internal Revenue, Respondent

Morrow v. Commissioner

Docket No. 112203

United States Tax Court

2 T.C. 210; 1943 U.S. Tax Ct. LEXIS 125;

June 23, 1943, Promulgated

Decision will be entered under Rule 50.

The purchase by petitioner of two annuity contracts providing for the payment of a total of $ 200 per month to an employee being retired after many years of valuable service, rendered with the understanding that retirement would be on a pension, held to be payment of additional compensation for such service and, accordingly, the cost of the annuity…

2Cases cited1 opinion

  1. Morrow v. CommissionerUnited States Tax Court · 1943

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