Dixon v. Commissioner
United States Tax Court
Mort Dixon, a prolific songwriter, received royalties from ASCAP which affected a formula under which the size of alimony payments to petitioner, his divorced wife, was determined. Their separation agreement, incorporated into the divorce decree, effectively provided that a percentage of such royalties should be paid to petitioner after Mort Dixon's death, and he implemented this provision by including a similar provision in his will.
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Mort Dixon, a prolific songwriter, received royalties from ASCAP which affected a formula under which the size of alimony payments to petitioner, his divorced wife, was determined. Their separation agreement, incorporated into the divorce decree, effectively provided that a percentage of such royalties should be paid to petitioner after Mort Dixon's death, and he implemented this provision by including a similar provision in his will. Held, such payments after Mort Dixon's death are taxable to petitioner under section 71(a), I.R.C. 1954.
1Opinion of the Court
Ada M. Dixon, Petitioner, v. Commissioner of Internal Revenue, Respondent
Dixon v. Commissioner
Docket No. 3239-63
United States Tax Court
44 T.C. 709; 1965 U.S. Tax Ct. LEXIS 41;
August 12, 1965, Filed
Decision will be entered under Rule 50.
Mort Dixon, a prolific songwriter, received royalties from ASCAP which affected a formula under which the size of alimony payments to petitioner, his divorced wife, was determined. Their separation agreement, incorporated into the divorce decree, effectively provided that a percentage of such royalties should be paid to petitioner after Mort Dixon's death, and…
Also in this document: Dissent.
2Cases cited16 opinions
- Rentways, Inc. v. O'Neill Milk & Cream Co.New York Court of Appeals · 1955
- Rastetter v. . HoenningerNew York Court of Appeals · 1915
- Sanford D. Beecher and William White, Jr., Executors of the Estate of John Richard Geary v. United StatesCourt of Appeals for the Third Circuit · 1960
- Twinam v. CommissionerUnited States Tax Court · 1954
- Alma v. Steele, Individually and as of the Estate of Charles F. Steele, Deceased v. Lelia M. McCargoCourt of Appeals for the Eighth Circuit · 1958
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