Commissioner of Internal Revenue v. Marie M. Newman

GARDNER, Chief Judge.

This matter is before us on petition of the Commissioner of Internal Revenue to review a decision of the Tax Court of the United States. The Commissioner determined deficiencies in respondent’s income tax for the years 1946 through 1953, occurring by reason of her failure to include in her gross income for such years certain alimony payments received by her.

Respondent and Floyd R. Newman were married in Cleveland, Ohio, February 28,1934, and thereafter continuously resided together as husband and wife until on or about January, 1945, at which time Floyd R. Newman left…