Tighe v. Commissioner
United States Tax Court
1. Petitioner's husband, who died in 1931, entered into an agreement with the person with whom he had been associated in the practice of law, providing that on the death of either partner the survivor would pay to the beneficiary named by the decedent (a) a sum certain each month for a period of 5 years, out of profits of the firm, and (b) an amount equal to the value of the decedent's interest in cases pending and assets of the firm.
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1. Petitioner's husband, who died in 1931, entered into an agreement with the person with whom he had been associated in the practice of law, providing that on the death of either partner the survivor would pay to the beneficiary named by the decedent (a) a sum certain each month for a period of 5 years, out of profits of the firm, and (b) an amount equal to the value of the decedent's interest in cases pending and assets of the firm. Petitioner brought suit against her deceased husband's former partner to collect the amounts due under the agreement and received $ 12,500.08 in settlement of…
1Opinion of the Court
OPINION.
Drennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for the year 1952 in the amount of $1,947.56.
The issues for decision are (1) whether certain payments, or any part thereof, received by petitioner in 1952 in settlement of a lawsuit instituted by her to collect amounts allegedly due under a contract executed by her deceased husband and a person with whom he was associated in the practice of law prior to his death constitute taxable income, and (2) the extent to which legal fees and expenses paid by petitioner to the attorneys who represented her in this suit…
2Cases cited15 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Helvering v. Estate of EnrightSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. TreganowanCourt of Appeals for the Second Circuit · 1950
- Helvering v. StormfeltzCourt of Appeals for the Eighth Circuit · 1944
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3Cited by21 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
- Buckley v. CommissionerUnited States Tax Court · 1962
- Essenfeld v. CommissionerUnited States Tax Court · 1961
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