This section contains the nature of the case and procedural background.

The Supreme Court for New York County entered a divorce between H and W. H was ordered to pay $3,000.00 every month for W’s support and maintenance. The Supreme Court for New York County entered a divorce for H and W. H was ordered to pay $3,000.00 every month for her support and maintenance. The issue is whether alimony payments constituted parts of W’s income and were subject to being taxed. W sued D claiming the payments were not income to her and that H was responsible for any tax on the monies used to create the net income to pay the alimony. H claimed that they were a tax-deductible expense. W got the judgment and the appeals court affirmed. The Supreme Court granted certiorari.

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