Hyde v. Commissioner
United States Tax Court
Pursuant to separation agreement and divorce decree H transferred to W (his wife) certain life insurance policies of which she became the absolute owner; thereafter, pursuant to the agreement and decree, H paid premiums on such policies. Held, such premiums represented alimony payments to W under section 71(a), I.R.C. 1954. Anita Quinby Stewart, 9 T.C. 195, followed. Florence H. Griffith, 35 T.C. 882, distinguished.
1Opinion of the Court
opinion.
Raum, Judge:
Respondent determined deficiencies in petitioner’s income tax in the amounts of $814.87 in 1954 and $873.16 in 1955. The only issue is whether the annual premiums of $1,892.99 paid by petitioner’s former husband in each of the taxable years on four life insurance policies previously assigned to her are includible in her gross income as periodic payments under a decree of divorce or written instrument incident thereto as provided in section 71(a) (1) of the Internal Revenue Code of 1954. The facts have been stipulated.
Petitioner resides at 1192 Park Avenue, New York, New…
2Cases cited12 opinions
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Powers v. CommissionerSupreme Court of the United States · 1941
- Carmichael v. CommissionerUnited States Tax Court · 1950
- Seligmann v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
- Weil v. CommissionerUnited States Tax Court · 1954
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3Cited by15 opinions
- Wright v. CommissionerUnited States Tax Court · 1974
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- Zampini v. CommissionerUnited States Tax Court · 1991
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