Furrow v. Commissioner
United States Tax Court
Decree of divorce dated July 20, 1954, required petitioner to pay to his former wife "as permanent alimony the sum of $ 36,000.00, payable at the rate of $ 300.00 per month, due and payable on the first day of each month, the first payment to become due and payable August 1, 1954." Held, that under the provisions of section 71(c), I.R.C. 1954, the $ 36,000 constituted the principal sum of an obligation of the petitioner, that payments made pursuant to the decree are…
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Decree of divorce dated July 20, 1954, required petitioner to pay to his former wife "as permanent alimony the sum of $ 36,000.00, payable at the rate of $ 300.00 per month, due and payable on the first day of each month, the first payment to become due and payable August 1, 1954." Held, that under the provisions of section 71(c), I.R.C. 1954, the $ 36,000 constituted the principal sum of an obligation of the petitioner, that payments made pursuant to the decree are installment payments in partial discharge of that obligation, that by the terms of the decree the principal sum is to be paid…
1Opinion of the Court
OPINION.
Withbt, Judge:
The respondent has determined deficiencies in the income taxes of the petitioners as follows:
Tear Deficiency
John W. Furrow, Jr_ 1954 $1, 071. 27 1955 2, 484. 00
John W., Jr., and Gloria Furrow. 1956 1,799.63
The only issue for determination is the correctness of the respondent’s action in disallowing deductions of $1,800, $3,600, and $3,600 taken for 1954, 1955, and 1956, respectively, for alimony payments made by John W. Furrow, Jr., to his former wife.
All of the facts have been stipulated and are found accordingly.
John W. Furrow, Jr., sometimes hereinafter referred to as…
2Cases cited10 opinions
- Gale v. CommissionerUnited States Tax Court · 1949
- Gale v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. GaleCourt of Appeals for the Second Circuit · 1951
- Commissioner of Internal Revenue v. Frank Polk and Marie PolkCourt of Appeals for the Tenth Circuit · 1960
- Polk v. CommissionerUnited States Tax Court · 1958
- Wick v. CommissionerUnited States Tax Court · 1946
5 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Wright v. CommissionerUnited States Tax Court · 1974
- John W., Jr. And Gloria Furrow v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1961
- Munderloh v. CommissionerUnited States Tax Court · 1967
- Clark v. CommissionerUnited States Tax Court · 1963
- Westbrook v. CommissionerUnited States Tax Court · 1980
10 more not listed; retrieve them via the Exa API.