Green v. Commissioner

T.C. Memo 1987-503 (1987)

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Green v. Commissioner

United States Tax Court
T.C. Memo 1987-503 (1987)

Facts

Green (plaintiff) and her partner shared a committed romantic relationship for nine years, until her partner’s death. Green’s partner was a stockbroker and owned a radio station, and Green assisted in his business activities and played the role, in her words, of an “old-fashioned traditional wife.” Green’s partner did not want to get married, but he promised to leave Green his entire estate when he died. However, upon Green’s partner’s death, his will directed that his $7,000,000 estate go to his siblings. Green sued the estate for the value of the services she had provided based on her partner’s promises to her. A jury found for Green on the theory of quantum meruit, and the Supreme Judicial Court of Massachusetts affirmed, remanding only on the issue of damages. Subsequently, Green and the estate settled her claim for $900,000 payable over two years. Green did not include those amounts as income on her tax returns in the years she received them. The commissioner of internal revenue (defendant) found a deficiency based on her failure to do so on the grounds that the settlement represented compensation for services, not a gift or bequest. Green argued that she merely performed wifely duties and that the settlement represented a gift or bequest.

Rule of Law

Issue

Holding and Reasoning (Wright, J.)

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Federal Income Tax

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