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    John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue, 226 F.2d 584, 3rd Cir. (1955)

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    The document is a court case from 1955 regarding whether certain payments made to John F. Beggy were taxable income or non-taxable gifts. The Tax Court had previously held that the payments were income. The Circuit Court affirms the Tax Court's decision without opinion, believing the Tax Court committed no error in its ruling that the payments were taxable compensation rather than excludable gifts.

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    John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue, 226 F.2d 584, 3rd Cir. (1955)

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    The document is a court case from 1955 regarding whether certain payments made to John F. Beggy were taxable income or non-taxable gifts. The Tax Court had previously held that the payments were income. The Circuit Court affirms the Tax Court's decision without opinion, believing the Tax Court committed no error in its ruling that the payments were taxable compensation rather than excludable gifts.

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    Filed: 1955-11-03 Precedential Status: Precedential Citations: 226 F.2d 584 Docket: 11593

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    The document is a court case from 1955 regarding whether certain payments made to John F. Beggy were taxable income or non-taxable gifts. The Tax Court had previously held that the payments were income. The Circuit Court affirms the Tax Court's decision without opinion, believing the Tax Court committed no error in its ruling that the payments were taxable compensation rather than excludable gifts.

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    Download as PDF or read online from Scribd
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    3 views1 page

    John F. Beggy and Rose A. Beggy v. Commissioner of Internal Revenue, 226 F.2d 584, 3rd Cir. (1955)

    Uploaded by

    Scribd Government Docs
    The document is a court case from 1955 regarding whether certain payments made to John F. Beggy were taxable income or non-taxable gifts. The Tax Court had previously held that the payments were income. The Circuit Court affirms the Tax Court's decision without opinion, believing the Tax Court committed no error in its ruling that the payments were taxable compensation rather than excludable gifts.

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    of 1

    226 F.

    2d 584
    55-2 USTC P 9742

    John F. BEGGY and Rose A. Beggy, Petitioners,


    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 11593.

    United States Court of Appeals Third Circuit.


    Argued Oct. 6, 1955.
    Decided Nov. 3, 1955.

    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.
    Before BIGGS, Chief Judge, and MARIS and GOODRICH, Circuit
    Judges.
    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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