Martin v. Commissioner
United States Tax Court
Petitioner is the widow of the former president of a family corporation. The corporation, under a directors' resolution, paid her amounts equivalent to her deceased husband's salary for 2 years. Held, petitioner has not shown that the payments received by her from the corporation were gifts. Estate of Mervin G. Pierpont, 35 T.C. 65, followed.
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in petitioners’ income tax for the taxable years 1955 and 1956 of $11,062.48 and $9,661.46, respectively. The sole question for decision is whether payments by a corporation to the widow of a corporate officer in the years in question constitute gifts or ordinary income taxable to the widow.1
FINDINGS OF FACT.
Some of the facts have been stipulated and they are found accordingly.
Petitioner Elizabeth E. Martin, hereinafter called petitioner, was the wife of Arthur Purdy, who died November 3, 1954. In 1955 she married Roy I. Martin of…
2Cases cited2 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Pierpont v. CommissionerUnited States Tax Court · 1960
3Cited by17 opinions
- Findlay v. CommissionerUnited States Tax Court · 1962
- Evans v. CommissionerUnited States Tax Court · 1962
- Roy I. Martin and Elizabeth E. Martin v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Gaugler v. United StatesDistrict Court, S.D. New York · 1962
- Bank of Palm Beach & Trust Co. v. United StatesUnited States Court of Claims · 1973
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