Beggy v. Commissioner
United States Tax Court
Gift or Compensation for Services. -- A payment for past services made by a corporation voluntarily and without legal obligation to an employee in connection with his resignation was not a gift but compensation taxable as ordinary income.
1Opinion of the Court
OPINION.
Muedoce, Judge:
The Commissioner determined a deficiency of $5,744.30 in income tax of the petitioners for 1950. The only issue for decision is whether $26,368.48 paid by Mine Safety Appliances Company to John F. Beggy in 1950 represented a gift within the meaning of section 22 (b) (3) of the Internal Revenue Code and therefore was excludable from his income. The parties have filed a stipulation of facts with exhibits, all of which are adopted as findings of fact.
The petitioners are husband and wife and they filed a joint income tax return for 1950 with the collector of internal…
2Cases cited4 opinions
- Carragan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Poorman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Nickelsburg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
3Cited by11 opinions
- Martin v. CommissionerUnited States Tax Court · 1988
- Jackson v. CommissionerUnited States Tax Court · 1956
- John F. Beggy and Rose A. Beggy v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Slattery v. United StatesUnited States Court of Claims · 1988
- BURDETT v. COMMISSIONERUnited States Tax Court · 1992
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