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THOMPSON v. COMMISSIONER

Docket No. 11618.

6 T.C.M. 822 (1947)

Clarissa H. Thomson v. Commissioner.

United States Tax Court.

Entered June 27, 1947.

Attorney(s) appearing for the Case

Roger W. Hardy, Esq., 53 State St., Boston, Mass., for the petitioner. Paul P. Lipton, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

Respondent determined a deficiency in gift tax for the year 1944 in the amount of $14,265. The only question is whether a payment of $94,000 which petitioner made to her then husband as part of a separation agreement represented a gift.

A gift tax return was filed with the collector for the district of Massachusetts.

Findings of Fact

Some facts have been stipulated. The stipulation...

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