U.S. Court of Appeals for the Third Circuit, 1955

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

John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Third Circuit · Decided November 3, 1955 · Biggs, Maris, Goodrich
226 F.2d 584; 48 A.F.T.R. (P-H) 290; 1955 U.S. App. LEXIS 4995 (Federal Reporter, Second Series)

Counsel

W. Denning Stewart, Pittsburgh, Pa. (H. Brian Holland, Asst. Atty. Gen., Rudy P. Hertzog, Acting Chief Counsel, Internal Revenue Bureau, Washington, D. C., on the brief), for petitioners., Kenneth E. Levin, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky, Sp. Assts. to Atty. Gen., on the brief), for respondent.

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

Cases that cite this one

3 later published cases cite this decision.

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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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