Legal Opinion

Estate of Siegel v. Commissioner

United States Tax Court

Decided June 30, 1980No. Docket No. 1685-76Published

Decedent entered into an agreement with his employer whereby he was to be paid an annual rate of compensation for performance of services for a fixed term of employment. The agreement provided that in the event of disability, decedent was to continue to receive payments under the agreement for the remainder of the term; in the event of death, the remaining payments were to be paid to decedent's children.

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Decedent entered into an agreement with his employer whereby he was to be paid an annual rate of compensation for performance of services for a fixed term of employment. The agreement provided that in the event of disability, decedent was to continue to receive payments under the agreement for the remainder of the term; in the event of death, the remaining payments were to be paid to decedent's children. The agreement further provided that decedent and his employer could mutually consent to modify the children's rights and interests under the agreement. Decedent died while a full-time…

1Opinion of the Court

Estate of Murray J. Siegel, Deceased, Frederick Zissu and Norman Lipshie, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Siegel v. Commissioner

Docket No. 1685-76

United States Tax Court

74 T.C. 613; 1980 U.S. Tax Ct. LEXIS 109;

June 30, 1980, Filed

Decedent entered into an agreement with his employer whereby he was to be paid an annual rate of compensation for performance of services for a fixed term of employment. The agreement provided that in the event of disability, decedent was to continue to receive payments under the agreement for the remainder of the term;…

2Cases cited33 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  3. Atlantic Northern Airlines, Inc. v. SchwimmerSupreme Court of New Jersey · 1953
  4. Danielson v. CommissionerUnited States Tax Court · 1965
  5. Helvering v. HelmholzSupreme Court of the United States · 1935

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