Legal Opinion

Aprill v. Commissioner

United States Tax Court

Decided November 8, 1949No. Docket No. 20091Published

Payments made to petitioner by the corporation formerly directed by her deceased husband without obligation on the part of the corporation and intended by it, in reliance on I. T. 3329, as a gift to her individually, held not taxable as either compensation for personal services or distribution of profits.

1Opinion of the Court

Louise K. Aprill, Petitioner, v. Commissioner of Internal Revenue, Respondent

Aprill v. Commissioner

Docket No. 20091

United States Tax Court

13 T.C. 707; 1949 U.S. Tax Ct. LEXIS 45;

November 8, 1949, Promulgated

Decision will be entered under Rule 50.

Payments made to petitioner by the corporation formerly directed by her deceased husband without obligation on the part of the corporation and intended by it, in reliance on I. T. 3329, as a gift to her individually, held not taxable as either compensation for personal services or distribution of profits.

Ed. J. deVerges, Esq., for the petitioner.

Donald…

2Cases cited2 opinions

  1. Bogardus v. CommissionerSupreme Court of the United States · 1937
  2. Aprill v. CommissionerUnited States Tax Court · 1949

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