¶1dissenting: By the agreement of May 10, 1951, decedent bound himself to make a testamentary bequest of a royalty interest to petitioner. He did just that and I would hold that petitioner, as she contends, takes under the will and not under the contract to make a will. The royalty interest received under the will would be taxable to her and I doubt if she would be .entitled to the depreciation she claims. See section 273, I.R.C. 1954, and respondent’s regulations thereunder.
44 T.C. 709
Dixon v. Commissioner
Decided August 12, 1965
United States Tax Court · decided 1965-08-12
Mort Dixon, a prolific songwriter, received royalties from ASCAP which affected a formula under which the size of alimony payments to petitioner, his divorced wife, was determined. Held: such payments after Mort Dixon's death are taxable to petitioner under section 71(a), I.R.C. 1954.
Good law ✅— No negative treatment on recordhow we know
Decision will be entered under Rule 50 · Decided 1965-08-12
How this case has been cited
Cited by 15 later decisions — most recently March 1997
2 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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