Hazel Porter v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Hazel Porter

This is a petition to review a decision of the Tax Court, which held that periodic payments by a husband to his divorced wife over a period of fifteen years pursuant to a divorce decree were taxable to the wife as ordinary income. Reference is made to the memorandum opinion of the Tax Court, T. C. Memo 1966-79, for a complete statement of facts.

It is the claim of the wife that these periodic payments were made to compensate her for her interest in shares of stock in the corporation in which her husband was the principal stockholder and that they did not represent payments for her support.

The…