Benjamin and Alice Fox v. United States
Court of Appeals for the Third Circuit
1Opinion of the Court
OPINION OF THE COURT
ALDISERT, Circuit Judge.
The question for decision is whether a husband settling a sum of $1,000,000 on his wife, pursuant to a divorce-related property settlement agreement, is entitled to a deduction under Section 483 of the Internal Revenue Code of imputed interest in the installment payments. The district court denied taxpayers’ claims for refund. This appeal followed. We affirm.
The facts giving rise to this dispute are neither complicated nor controverted. On March 20, 1967, Benjamin Fox and his then wife, Juliette, contemplating divorce, entered into a written…
2Cases cited5 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Commissioner v. LesterSupreme Court of the United States · 1961
- Commissioner of Internal Revenue v. MestaCourt of Appeals for the Third Circuit · 1941
- Albert J. Faber v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Claus A. Cosman and Dorothy Cosman v. The United StatesUnited States Court of Claims · 1971
3Cited by20 opinions
- Gammill v. CommissionerUnited States Tax Court · 1980
- Gammill v. CommissionerCourt of Appeals for the Tenth Circuit · 1982
- Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Catterall v. CommissionerUnited States Tax Court · 1977
- Kohn v. KohnSuperior Court of Pennsylvania · 1976
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