Pierson v. Commissioner

OPINION.

Nice, Judge:

Petitioner argues that $1,100 of the total sum of $2,100, which she received from the Arthur N. Pierson Corporation in 1948, is not taxable to her as alimony income because it represented a gift from the company. This is true, she says, because the company was not reimbursed by her former husband nor could it deduct such amount from his salary, since it was then inactive.

We think this argument is totally without merit. Petitioner received and accepted such sum from the corporation in satisfaction of her husband’s obligation for support and maintenance under the divorce…