Legal Opinion

White v. Commissioner

United States Tax Court

Decided February 6, 1984No. Docket Nos. 7256-76, 7754-76PublishedCited by 4 opinions

Husband and wife negotiated and entered into an agreement under which husband was to pay specified amounts to wife as installment payments of a principal sum obligation in lieu of support payments. The terms of the agreement were subsequently incorporated by a judgment of divorce. Husband thereafter made all payments to wife as required. The provision for support payments consisted of a paragraph divided into two subparagraphs. Under subpar.

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Husband and wife negotiated and entered into an agreement under which husband was to pay specified amounts to wife as installment payments of a principal sum obligation in lieu of support payments. The terms of the agreement were subsequently incorporated by a judgment of divorce. Husband thereafter made all payments to wife as required. The provision for support payments consisted of a paragraph divided into two subparagraphs. Under subpar. (a), certain indefeasible sums were to be paid in monthly installments over a 6-year period. Under subpar. (b), certain additional sums were to be paid…

1Opinion of the Court

Hamblen, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes as follows:

Year Robert P. White Nancy S. White

1969 . $14,170

1970 . 16,283

1971.$19,473 14,565

1972. 16,466 14,197

1973. 17,937 14,182

1974. 14,765 14,431

The primary issue1 for decision is whether or not certain payments made by petitioner Robert P. White (hereinafter Robert) to his former wife, petitioner Nancy S. White (hereinafter Nancy), are properly deductible by him and includable by her in gross income. In the event that this issue is determined adversely to Nancy, then we must also decide whether the…

2Cases cited16 opinions

  1. Elizabeth H. Bardwell v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  2. Bardwell v. CommissionerUnited States Tax Court · 1962
  3. Thompson v. CommissionerUnited States Tax Court · 1968
  4. Jackson v. CommissionerUnited States Tax Court · 1970
  5. Gammill v. CommissionerUnited States Tax Court · 1980

11 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Nancy S. White v. Commissioner of Internal Revenue, Robert P. White v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
  2. White v. Touche Ross & Co.Appellate Court of Illinois · 1987
  3. Springer v. Comm'rUnited States Tax Court · 2003
  4. White v. CommissionerUnited States Tax Court · 1984

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