Hatch v. Commissioner of Internal Revenue

SWAN, Circuit Judge.

The petitioner is the widow and sole legatee of Frederic H. Hatch, who died April 2, 1930. Among the decedent’s assets was a contract, dated May 19, 1928, by the terms of which Frederic H. Hatch & Co., a corporation, agreed to employ him for ten years at an annual salary of $30,000 and, in the event of his death, agreed to pay the annual salary to his estate for ten years beginning on the date of death. The corporation also assumed an obligation contingent on the amount of the corporation’s net earnings to pay his estate an additional sum, but no payment was ever made…