John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue

Third Circuit

John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue

226 F.2d 584, 48 A.F.T.R. (P-H) 290, 1955 U.S. App. LEXIS 4995

Court of Appeals for the Third Circuit·Decided November 3, 1955·No. 11593·Published·Cited by 5 cases

Opinion

PER CURIAM.

The question is whether certain payments made to the taxpayer, John F. Beggy, were gifts within the meaning of Section 22(b) of the Internal Revenue Code, 1939, 26 U.S.C.A. § 22(b), or constituted compensation to Beggy and therefore were income within the meaning of Section 22(a). The Tax Court held that the payments were income. We have considered the issue and are convinced that no error was committed by the Tax Court and therefore its decision will be affirmed on the opinion of Judge Murdock, 23 T.C. 736.

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PER CURIAM.

The question is whether certain payments made to the taxpayer, John F. Beggy, were gifts within the meaning of Section 22(b) of the Internal Revenue Code, 1939, 26 U.S.C.A. § 22(b), or constituted compensation to Beggy and therefore were income within the meaning of Section 22(a). The Tax Court held that the payments were income. We have considered the issue and are convinced that no error was committed by the Tax Court and therefore its decision will be affirmed on the opinion of Judge Murdock, 23 T.C. 736.

John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue, 226 F.2d 584, 48 A.F.T.R. (P-H) 290, 1955 U.S. App. LEXIS 4995 (3d Cir. 1955).

Pincite

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Opinion

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