Martha W. Collord Fryer v. Commissioner of Internal Revenue

Martha W. Collord Fryer appeals from a decision of the Tax Court, Tannenwald, J., holding that there was a deficiency of $228 for the year 1966. In that year, appellant received a total of $5,200 from her former husband pursuant to a separation agreement. The issue before the Tax Court was whether $2,600 of that amount should have been taxed to appellant as alimony or excluded from her income as child support. Although the Tax Court had “little doubt” that the parties intended “to provide $50 per week as alimony and $25 per week for the support of each of the two minor children,” it held that…