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Estate of Carter v. Commissioner
''Estate of Sydney J. Carter v. Commissioner of Internal Revenue'', 453 F.2d 61, 62 (2d Cir. 1971), was a United States income tax case decided by Judge Henry Friendly.
==Facts==
Dorothy T. Carter, the widow of Sydney J. Carter, was the taxpayer and appellant in the case. Mrs. Carter had been paid by Mr. Carter's employer what he would have earned until the end of the fiscal year. Mrs. Carter did not include that amount as income on a joint return she filed. The joint return for 1960 filed by Mrs. Carter as executrix and for herself did not report as income the payments of $60,130.84, although it did report as capital gain a payment of $52,337.68, less the deduction of $5,000 permitted by I.R.C. § 101(b)(2)(A) (), from the trustees of the Salomon Bros. Profit Sharing Plan, which represented the amounts accumulated for Sydney Carter's benefit during his years of service.
The Commissioner assessed a deficiency for failure to include the former amount. The Commissioner's assessment was sustained by the United States Tax Court. Mrs. Carter appealed to the Court of Appeals for the Second Circuit.
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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