Byrnece S. Green v. Commissioner of Internal Revenue

Byrnece Green appeals from a decision and order of the United States Tax Court (Wright, J.) entered October 22, 1987 that determined deficiencies of $41,709.93 and $253,083.00 in income tax due from her for the tax years 1977 and 1978, respectively.

The facts are not in dispute. Byrnece Green met Maxwell Richmond on November 18,1962. Ms. Green, then 36 years old, was a divorced secretary who lived in Boston with her 15-year old son. Richmond was a wealthy, 49-year old bachelor, whose holdings included licenses to operate three radio stations. After meeting Richmond, Green became a stockbroker…