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ESTATE OF HIRSHON v. COMMISSIONER

Docket Nos. 57896, 61658.

27 T.C. 558 (1956)

ESTATE OF DOROTHY R. HIRSHON, DECEASED, WALTER HIRSHON, EXECUTOR, AND WALTER HIRSHON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JEAN McGRAW HIRSHON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 21, 1956.

Attorney(s) appearing for the Case

John P. Allison, Esq., for the petitioners.

Emil Sebetic, Esq., for the respondent.

OPINION.

RAUM, Judge:

The principal question for decision is whether certain amounts paid to a former wife in 1951 are deductible in full as alimony under section 23 (u) of the Internal Revenue Code of 1939, or whether a portion of those payments was allocable to the support of a minor child within the meaning of section 22 (k) and therefore not deductible by the husband under section 23 (u) or includible in the former wife's gross income under section...

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