Legal Opinion

Wright v. Commissioner

United States Tax Court

Decided December 27, 1962No. Docket Nos. 83276, 84068, 86440PublishedCited by 3 opinions

Decedent, who had solicited insurance for a British firm on a commission basis, executed an agreement in 1936 providing for the payment of commissions after his death in designated amounts and for a limited period. He bequeathed one-half of the commission payments to petitioner, his surviving spouse.

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Decedent, who had solicited insurance for a British firm on a commission basis, executed an agreement in 1936 providing for the payment of commissions after his death in designated amounts and for a limited period. He bequeathed one-half of the commission payments to petitioner, his surviving spouse. Decedent died in 1951 and petitioner agreed in 1952 and 1953 to accept $ 150,000 in full settlement of her claim, and also agreed to a reduction in her payments for a portion of amounts required to pay British death duty. Petitioner received $ 50,000 from the British insurance brokers in each of…

1Opinion of the Court

MtjlRONey, Judge:

The respondent determined deficiencies in the petitioners’ income tax as follows:

Docket No: 84068

Tear Deficiency

1953_$32,188.68

1954_ 29, 736. 36

1955_ 33, 321. 50

Docket No. 88276

Tear Deficiency

1956_ $9, 267.18

Docket No. 86440

Tear Deficiency

1957-$10, 387. 50

1958- 10,927.23

Petitioners claim an overpayment of income tax in the year 1953 in the amount of $3,530.50. The issues in these consolidated cases are (1) whether certain payments received by petitioners in 1953, 1954, and 1955 constitute income in respect of a decedent within the meaning of section 126 of tRe Internal…

2Cases cited1 opinion

  1. Findlay v. CommissionerUnited States Tax Court · 1962

3Cited by3 opinions

  1. Dr. Irving S. Wright and Lois E. Wright v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
  2. Plastic Binding Corp. v. CommissionerUnited States Tax Court · 1967
  3. Wright v. CommissionerUnited States Tax Court · 1962

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