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Estate of Sydney Carter v. Commissioner

453 F.2d 61 (1971)

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Estate of Sydney Carter v. Commissioner

United States Court of Appeals for the Second Circuit
453 F.2d 61 (1971)

JR

Facts

At the time of his death on March 1, 1960, Sydney J. Carter (plaintiff) had worked at a financial firm for 38 years. In the year he died, Sydney was working under an employment contract that authorized him to receive his annual salary and a percentage of the firm’s net profits if he was still employed there on September 30, 1960. Despite not having a formal or informal plan to pay the survivors of deceased employees, the firm’s administrative committee decided to pay Carter’s widow, Mrs. Carter, the remainder of his yearly salary and his portion of the firm’s annual net profits. The firm decided this due to Sydney’s frequent hospitalizations and because they knew Mrs. Carter from her time as their secretary 28 years prior. Mrs. Carter did not report the payment as income on the joint return filed for herself and Sydney’s estate. The Internal Revenue Commissioner (the commissioner) (defendant) assessed a deficiency. Mrs. Carter petitioned the United States Tax Court for relief but, it agreed with the commissioner. Mrs. Carter appealed.

Rule of Law

Issue

Holding and Reasoning (Friendly, J.)

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Federal Income Tax

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