SMITH v. COMMISSIONER

Docket No. 26612.

16 T.C. 639 (1951)

DOROTHY BRIGGS SMITH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 28, 1951.


Attorney(s) appearing for the Case

Walter F. Gibbons, Esq., for the petitioner.

Joseph Landis, Esq., for the respondent.

Robert F. Pickard, Esq., amicus curiae.


The Commissioner has determined a deficiency of $1,182.52 in petitioner's income tax liability for 1948.

The issue in this proceeding is whether the payment of $5,000 made to petitioner by her divorced husband is includible in her income under section 22 (k).

Petitioner, who was a resident of Providence, filed her return with the collector for the district of Rhode Island.

FINDINGS OF FACT.

The facts...

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