Estate of Thoda v. Commissioner
United States Tax Court
1. Held: Payments made by Gurley to Mrs. Thoda referred to in settlement agreement as installment payments of a specific sum of alimony in solido were in the nature of a property settlement rather than alimony and were not taxable to Mrs. Thoda under sec. 71, I.R.C. 1954, nor deductible by Gurley under sec. 215, I.R.C. 1954. 2. Amount of Gurley's charitable contributions determined.
1Opinion of the Court
ESTATE OF SHIRLEY JOY THODA, DECEASED, WILLIAM H. THODA, EXECUTOR, and CONNIE MACK GURLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Thoda v. Commissioner
Docket Nos. 1529-77, 4536-77.
United States Tax Court
T.C. Memo 1979-219; 1979 Tax Ct. Memo LEXIS 307; 38 T.C.M. (CCH) 880; T.C.M. (RIA) 79219;
May 30, 1979, Filed
1. Held: Payments made by Gurley to Mrs. Thoda referred to in settlement agreement as installment payments of a specific sum of alimony in solido were in the nature of a property settlement rather than alimony and were not taxable to Mrs. Thoda under sec.…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Elizabeth H. Bardwell v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Bardwell v. CommissionerUnited States Tax Court · 1962
- Key Buick Co. v. CommissionerUnited States Tax Court · 1977
- Thompson v. CommissionerUnited States Tax Court · 1968
8 more not listed; retrieve them via the Exa API.