Legal Opinion

Corasaniti v. United States

District Court, D. Maryland

Decided December 31, 1962No. Civ. 13878PublishedCited by 4 opinions

1Opinion of the Court

THOMSEN, Chief Judge.

This is an action for the recovery of income taxes alleged to have been illegally assessed. The question is whether weekly payments by a corporation to a widow for a period of two years in the amount of her deceased husband’s salary constituted taxable income to the widow or a gift. This Court will follow the three steps towards reaching a conclusion prescribed by Poyner v. C. I. R., 4 Cir., 301 F.2d 287, 289.

I. Basic Facts

Some of the basic facts are stipulated or undisputed, but some findings have required the Court to resolve conflicting testimony.

The plaintiff Anna is…

2Cases cited10 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Bogardus v. CommissionerSupreme Court of the United States · 1937
  3. Mildred W. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
  4. Luntz v. CommissionerUnited States Tax Court · 1958
  5. Hilda Bounds v. United StatesCourt of Appeals for the Fourth Circuit · 1958

5 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Estate of Sydney J. Carter, Deceased (A/k/a Sydney J. Canter) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1971
  2. Froehlinger v. United StatesDistrict Court, D. Maryland · 1963
  3. Elsie F. Greentree v. United StatesCourt of Appeals for the Fourth Circuit · 1964
  4. Estate of Sydney J. Carter, Deceased (A/k/a Sydney J. Canter) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1971

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