Nathan Agar and Christina Edith Agar v. Commissioner of Internal Revenue

Petitioner, Nathan Agar, seeks review of the Tax Court’s decision that payments made to him by McGregor-Doni-ger, Inc., after he had resigned as its treasurer should have been declared as income since the payments were not, as petitioner claimed, exempt from taxation as “damages received * * * on account of [personal] injuries.” 26 U.S.C. § 22(b) (5) (1939 Code); 26 U.S.C. § 104(a) (2) (1954 Code). We affirm since the Tax Court’s finding that the payments were made “as ‘extra’ compensation for services rendered by petitioner over his years of service to Doniger” was not clearly erroneous.

Agar,…