Legal Opinion

Estate of Porter v. Commissioner

United States Tax Court

Decided May 25, 1970No. Docket No. 1397-68Published

Decedent, approximately 3 weeks before his death, entered into identical contracts with three corporations of which he was an officer and employee, under which as an inducement to the decedent to remain in their employ, the corporations agreed to make certain payments to his surviving spouse or issue if the decedent was in the employ of each of those corporations at his death.

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Decedent, approximately 3 weeks before his death, entered into identical contracts with three corporations of which he was an officer and employee, under which as an inducement to the decedent to remain in their employ, the corporations agreed to make certain payments to his surviving spouse or issue if the decedent was in the employ of each of those corporations at his death. The contracts provided that they were to be binding on the successors, heirs, executors, and administrators of the parties and could not be terminated or altered without the written consent of all parties. Held, the…

1Opinion of the Court

Estate of Bernard L. Porter, Deceased, Ruth R. Porter, Alexander H. Porter, and Saul A. Seder, Administrators D/B/N C/T/A, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Porter v. Commissioner

Docket No. 1397-68

United States Tax Court

54 T.C. 1066; 1970 U.S. Tax Ct. LEXIS 134;

May 25, 1970, Filed

Decision will be entered under Rule 50.

Decedent, approximately 3 weeks before his death, entered into identical contracts with three corporations of which he was an officer and employee, under which as an inducement to the decedent to remain in their employ, the corporations agreed…

Also in this document: Concurrence · Tannenwald; Concurrence · Quealy; Dissent.

2Cases cited51 opinions

  1. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  2. United States v. JacobsSupreme Court of the United States · 1939
  3. Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
  4. United States v. Estate of GraceSupreme Court of the United States · 1969
  5. Piper v. ChildsMassachusetts Supreme Judicial Court · 1935

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