Aprill v. Commissioner
United States Tax Court
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
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Aprill v. CommissionerUnited States Tax Court · 1949