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EST. OF FRED L. SPICKNALL v. COMMISSIONER

Docket No. 64200.

18 T.C.M. 1029 (1959)

T.C. Memo. 1959-213

Estate of Fred L. Spicknall, Deceased, Katherine Spicknall, Administratrix, and Katherine Spicknall v. Commissioner.

United States Tax Court.

Filed November 9, 1959.

Attorney(s) appearing for the Case

J. A. Shaw, Esq., and T. Hartley Pollock, Esq., for the petitioners. Ivan L. Onnen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

This proceeding involves deficiencies in Federal income tax of the petitioners for the years 1952 and 1953 in the respective amounts of $462.98 and $3,468.26. The sole issue is whether alimony payments made by Fred Spicknall to his former wife were periodic payments within the meaning of section 22(k) and hence deductible under section 23(u), Internal Revenue Code of 1939.

Findings of Fact

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