Estate of Harrison v. Commissioner
United States Tax Court
1. After disagreement between decedent, then president of American Maritime Association (AMA), and certain members of that organization representing trade unions, decedent agreed to resign his position as president in return for a 5-year consulting agreement, including a provision not to compete, with AMA under which $ 50,000 would be, and was, placed in trust in 1965. This sum and income therefrom was to be paid to him or his heirs in five annual installments.
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1. After disagreement between decedent, then president of American Maritime Association (AMA), and certain members of that organization representing trade unions, decedent agreed to resign his position as president in return for a 5-year consulting agreement, including a provision not to compete, with AMA under which $ 50,000 would be, and was, placed in trust in 1965. This sum and income therefrom was to be paid to him or his heirs in five annual installments. Upon termination of his duties as AMA's president in 1965, decedent moved his residence from Short Hills, N.J., to Mobile, Ala., and…
1Opinion of the Court
Stebrett, Judge:
The respondent determined deficiencies in petitioners’ Federal income taxes and additions thereto under section 6653 (a), I.R.C. 1954,1 as follows:
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Certain issues haying either been conceded or not raised in the petition, the remaining issues presented for determination -are: (1) Whether $50,000 placed in trust in 1965 and payable in five annual installments to James Max Harrison or his heirs pursuant to a consulting agreement, including a provision not to compete, is taxable income in that year; (2) whether expenses incurred in moving from New Jersey to Alabama…
2Cases cited10 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Freuler v. HelveringSupreme Court of the United States · 1934
- Commissioner v. SmithSupreme Court of the United States · 1945
- Sproull v. CommissionerUnited States Tax Court · 1951
- Sutor v. CommissionerUnited States Tax Court · 1951
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Richardson v. CommissionerUnited States Tax Court · 1975
- Sammy R. And Pamela Kay Dillon v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Jolar Cinema, Inc. v. CommissionerUnited States Tax Court · 1983
- Hoelzer v. CommissionerUnited States Tax Court · 1982
- Allen v. CommissionerUnited States Tax Court · 1982
4 more not listed; retrieve them via the Exa API.