Legal Opinion

Doty v. Commissioner

United States Tax Court

Decided September 28, 1983No. Docket No. 16089-80PublishedCited by 2 opinions

Petitioner is the former wife of Charles M. Schulz, the creator and author of the comic strip "Peanuts." At the time of his separation and divorce from petitioner, Mr. Schulz produced the "Peanuts" comic strip for United Feature Syndicate, Inc., pursuant to a syndicate agreement under which he received royalties equal to 50 percent of the net cash proceeds the syndicate realized from the distribution of daily and Sunday comic strips and the licensing of the "Peanuts"…

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Petitioner is the former wife of Charles M. Schulz, the creator and author of the comic strip "Peanuts." At the time of his separation and divorce from petitioner, Mr. Schulz produced the "Peanuts" comic strip for United Feature Syndicate, Inc., pursuant to a syndicate agreement under which he received royalties equal to 50 percent of the net cash proceeds the syndicate realized from the distribution of daily and Sunday comic strips and the licensing of the "Peanuts" characters. In their marriage settlement agreement, Mr. Schulz and petitioner agreed that under California law, she possessed a…

1Opinion of the Court

Sterrett, Judge:

By notice of deficiency dated June 12, 1980, respondent determined deficiencies in petitioners’ Federal income taxes in the amounts of $107,916, $92,976, and $118,743 for the years 1975, 1976, and 1977, respectively. The sole issue for decision is whether the income received by petitioner Joyce Doty pursuant to her marriage settlement agreement constituted earned income under former section 1348, I.R.C. 1954.1

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts together with the exhibits attached thereto are incorporated herein by…

2Cases cited21 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Poe v. SeabornSupreme Court of the United States · 1930
  3. In Re Marriage of BrownCalifornia Supreme Court · 1976
  4. United States v. MitchellSupreme Court of the United States · 1971
  5. HCSC-Laundry v. United StatesSupreme Court of the United States · 1981

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3Cited by2 opinions

  1. Heidrich v. CommissionerUnited States Tax Court · 1971
  2. Doty v. CommissionerUnited States Tax Court · 1983

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