[DOWNLOAD] "Poyner v. Commissioner of Internal Revenue" by United States Court of Appeals * eBook PDF Kindle ePub Free
eBook details
- Title: Poyner v. Commissioner of Internal Revenue
- Author : United States Court of Appeals
- Release Date : January 21, 1962
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 66 KB
Description
Not the least of the difficulties often faced by a recently widowed woman is the loss of her husbands financial support. However, for many widows of ranking employees in companies, this cause for worry has been alleviated by the practice of the employer making payments to the widow for limited periods following the husbands death, frequently by continuing to pay her the salary her husband would have received had he lived. The Commissioner of Internal Revenue has since 1950 sought to treat such payments as ordinary income to the widow under the general provisions of section 61 of the Internal Revenue Code, 26 U.S.C.A. Γ§ 61 The widows, on the other hand, have contended with considerable success in the courts that the payments were gifts, hence not includible in gross income under section 102 The issue in the present case is of this character. We are asked by a widow to reverse a decision of the Tax Court which treats as ordinary income the payments made to her by a corporation of which for 38 years her husband had been president and majority stockholder