Legal Opinion

Siegert v. Commissioner

United States Tax Court

Decided January 15, 1969No. Docket No. 2390-66PublishedCited by 6 opinions

Held, payments made by petitioner's former husband to her pursuant to order of a responding State court under provisions of the Uniform Reciprocal Enforcement of Support Act upon her petition for support of a minor child are not alimony, includable in petitioner's income under sec. 71 of the 1954 Internal Revenue Code.

1Opinion of the Court

OPINION

Hoyt, Judge:

Respondent determined the following income tax deficiencies against petitioner:

Tamable year Deficiency

1962 _ $216

1963 _ 214

1964 _ 196

The sole issue for decision is whether amounts paid to the petitioner by her former husband under a court decree pursuant to the Uniform Reciprocal Enforcement of Support Laws of Florida and Virginia were alimony payments under section'll (a) ,1

All of the facts have been stipulated and are found accordingly. The stipulation of facts, together with the related exhibits, are incorporated herein by this reference. Ines Siegert, the petitioner,…

2Cases cited5 opinions

  1. Commissioner v. LesterSupreme Court of the United States · 1961
  2. Arthur G. B. Metcalf v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1965
  3. Thomson v. CommissionerUnited States Tax Court · 1964
  4. Tinsman v. CommissionerUnited States Tax Court · 1967
  5. Clark v. ClarkDistrict Court of Appeal of Florida · 1962

3Cited by6 opinions

  1. Carle v. CommissionerUnited States Tax Court · 1970
  2. Cain v. CommissionerUnited States Tax Court · 1976
  3. Carle v. CommissionerUnited States Tax Court · 1970
  4. Delehanty v. CommissionerUnited States Tax Court · 1977
  5. Siegert v. CommissionerUnited States Tax Court · 1969

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