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ESTATE OF HILL v. COMMISSIONER

Docket No. 7483.

5 T.C.M. 55 (1946)

Estate of Julien H. Hill, State-Planters Bank and Trust Co., Executor v. Commissioner.

United States Tax Court.

Entered January 31, 1946.

Attorney(s) appearing for the Case

John F. Greaney, Esq., Earle Bldg., Washington, D. C., for the petitioner. Elmer L. Corbin, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined a deficiency of $11,496.37 in gift tax for the calendar year 1942. The sole issue is whether a lump sum payment of $70,000, or any portion thereof, made by Julien H. Hill (hereinafter referred to as decedent) to his wife in 1942, during the pendency of divorce proceedings and incident thereto, in settlement solely of his wife's right to support and maintenance, is taxable as a gift...

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