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PIERPONT v. COMMISSIONER

Docket No. 78066.

35 T.C. 65 (1960)

ESTATE OF MERVIN G. PIERPONT, DECEASED, ERNEST L. POYNER AND UNION TRUST COMPANY OF MARYLAND, EXECUTORS, AND LALLAH R. PIERPONT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 19, 1960.

Attorney(s) appearing for the Case

Mannes F. Greenberg, Esq., for the petitioners.

Joseph N. Ingolia, Esq., for the respondent.

OPINION.

RAUM, Judge.

The Commissioner determined a $1,376.22 deficiency in petitioners' 1956 income tax, resulting from his addition to their taxable income of "salary continuation payments" in the amount of $4,910.05, explained by him as follows:

(a) It is held that salary continuation payments of $9,910.05 paid to Mrs. Pierpont in 1956 by the Loewy Drug Co. in consideration of her deceased husband's services to that corporation constitutes...

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