Estate of Hellstrom v. Commissioner

OPINION.

Hice, Judge:

Petitioner claims that the sums paid to her by the Hellstrom Corporation in 1952 were a gift. As indicated by our findings, we agree that such sums were a gift and, hence, excludible from her gross income in that year.

The substance of the respondent’s argument and the basis of his determination is his Ruling I. T. 4027,1950-2 C. B. 9,11, which states “that payments made by an employer to the widow of a deceased officer or employee, in consideration of services rendered by the officer or employee, are includible in the gross income of the widow for Federal tax purposes.” He…