Carmichael v. Commissioner
United States Tax Court
Petitioner was obligated under both a divorce decree and agreement incident thereto to pay both his wife and daughter, as alimony to the former and maintenance to the latter, cash installments of a specified principal sum over a period of 9 years. By the same instruments he was required to place insurance policies on his life in escrow to secure payment of a portion of the principal sums due and payable to the wife and daughter.
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Petitioner was obligated under both a divorce decree and agreement incident thereto to pay both his wife and daughter, as alimony to the former and maintenance to the latter, cash installments of a specified principal sum over a period of 9 years. By the same instruments he was required to place insurance policies on his life in escrow to secure payment of a portion of the principal sums due and payable to the wife and daughter. Finally, the decree and agreement incident thereto obligated him to vest title to an insurance policy on his life in his wife as additional alimony, and vest title to…
1Opinion of the Court
OPINION.
Hill, Judge:
From July 21, 1945, when Vieva Carmichael was granted a divorce, until December 31, 1945, petitioner paid $1,300 to his former wife in the form of cash installments of alimony, $274.30 as premiums on life insurance policies held in escrow, and $500.90 as premiums on two life insurance policies which he had delivered to her, or a grand total of $2,075.20. The sole question for our determination is whether all or any portion of this $2,075.20 was in-cludible in the gross income of Vieva Carmichael for 1945 under section 22 (k) of the code and thus was deductible by…
2Cases cited4 opinions
- Steinel v. CommissionerUnited States Tax Court · 1948
- Stewart v. CommissionerUnited States Tax Court · 1947
- Blumenthal v. CommissionerUnited States Tax Court · 1949
- Hart v. CommissionerUnited States Tax Court · 1948
3Cited by51 opinions
- Wright v. CommissionerUnited States Tax Court · 1974
- Norton v. CommissionerUnited States Tax Court · 1951
- Seligmann v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
- Carbine v. CommissionerUnited States Tax Court · 1984
- Weil v. CommissionerUnited States Tax Court · 1954
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