de Canizares v. Commissioner
United States Tax Court
1. Held, that the payments of $ 8,000 which petitioner received in each of the taxable years 1951 to 1954, inclusive, were annuity payments which she received under a contract which she entered into with R. H. Johnson Company on October 27, 1943, by which she transferred to the company 117 shares of stock in the company which she had received as a bequest from her husband who died July 31, 1943. Petitioner is taxable on such annuity payments as provided under the statutes…
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1. Held, that the payments of $ 8,000 which petitioner received in each of the taxable years 1951 to 1954, inclusive, were annuity payments which she received under a contract which she entered into with R. H. Johnson Company on October 27, 1943, by which she transferred to the company 117 shares of stock in the company which she had received as a bequest from her husband who died July 31, 1943. Petitioner is taxable on such annuity payments as provided under the statutes taxing annuity payments -- Internal Revenue Code of 1939 for the years 1951, 1952, and 1953, and Internal Revenue Code of…
1Opinion of the Court
OPINION.
Blacb;, Judge:
The Commissioner has included in petitioner’s gross income for each of the years 1951 to 1954, inclusive, the sum of $8,000 which she received in each of those taxable years from the company under the terms of an agreement which she entered into with the company on October 27,1943.
The petitioner contests this determination of the Commissioner and states the issues in her brief as follows:(1) whether the amounts received by petitioner during each of the years involved from E. H. Johnson Co. were excludible from gross income as being in the nature of a gift or bequest and…
2Cases cited4 opinions
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Smith v. CommissionerUnited States Tax Court · 1953
- Raymond v. CommissionerUnited States Board of Tax Appeals · 1939
- Raymond v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
3Cited by7 opinions
- 212 Corp. v. CommissionerUnited States Tax Court · 1978
- Estate of Bell v. CommissionerUnited States Tax Court · 1973
- Turner v. CommissionerUnited States Tax Court · 1960
- 212 Corp. v. CommissionerUnited States Tax Court · 1978
- Ballard v. CommissionerUnited States Tax Court · 1992
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