Hatch v. Commissioner
United States Tax Court
In 1928 the petitioner's husband entered into an employment agreement with a recently organized corporation under which he was to render service to the corporation for a period of ten years and was not to engage in any other business or occupation during the period of his employment.
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In 1928 the petitioner's husband entered into an employment agreement with a recently organized corporation under which he was to render service to the corporation for a period of ten years and was not to engage in any other business or occupation during the period of his employment. Upon his death in 1930 the corporation, pursuant to the terms of the agreement, became obligated to pay his estate $ 30,000 annually for ten years and in certain contingencies to pay a percentage of its annual net earnings during the same period. As sole beneficiary of the will of her husband, the petitioner…
1Opinion of the Court
OPINION.
Turnee, Judge:
It is the contention of the petitioner that the $7,-923.30 received by her in 1941 and the $12,000 received in each of the years 1942 and 1943 under the contract between Frederic H. Hatch and Frederic H. Hatch & Co., which contract was acquired by her as legatee under the will of Frederic H. Hatch, were not income to her as determined by the respondent. It is her contention that the amounts in question constituted bequests, devises, or inheritances and are therefore specifically excluded from gross income by the provisions of section 22 (b) (3) of the Internal Revenue…
2Cases cited3 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Carter v. CommissionerUnited States Tax Court · 1947
- Nicholson v. CommissionerUnited States Tax Court · 1944
3Cited by20 opinions
- Commissioner of Internal Revenue v. LindeCourt of Appeals for the Ninth Circuit · 1954
- Underhill v. CommissionerUnited States Tax Court · 1966
- Osenbach v. CommissionerUnited States Tax Court · 1951
- Liftin v. CommissionerUnited States Tax Court · 1961
- Chamberlin v. CommissionerUnited States Tax Court · 1959
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