Wright v. Commissioner
United States Tax Court
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
- Findlay v. CommissionerUnited States Tax Court · 1962
3Cited by3 opinions
- Dr. Irving S. Wright and Lois E. Wright v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Plastic Binding Corp. v. CommissionerUnited States Tax Court · 1967
- Wright v. CommissionerUnited States Tax Court · 1962