¶1I agree with much that is said by Judge Kern in his dissenting opinion. In my judgment Freeman and his wife should be taxed annually upon the amounts received. This would be reasonable and fair to the fiscus and to the taxpayers and the administrative difficulties mentioned in the concluding paragraph of the opinion in Charles L.. Jones, 2 T. C. 924, would be obviated.
4 T.C. 582
Freeman v. Commissioner
Decided January 16, 1945
United States Tax Court · decided 1945-01-16
Gross Income -- Compensation for Services -- Annuities. -- The cost of annuity contracts purchased for an employee and received by him in satisfaction of his employer's promise to pay compensation for services is taxable income to the employee in the year of receipt, following Richard R. Deupree, 1 T. C. 113, and Renton K. Brodie, 1 T. C. 275.
Cited by 8 later decisions — most recently June 1963
1 federal appellate ·
Relies on Jones v. Commissioner
Good law ✅— No negative treatment on recordhow we know
Decision will be entered for the respondent · Decided 1945-01-16
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