Anesthesia Service Medical Group, Inc. v. Commissioner of Internal Revenue Service

WIGGINS, Circuit Judge:

Taxpayer Anesthesia Service Medical Group, Inc. (ASMG) appeals from the Tax Court’s decision finding deficiencies in its tax payments in the years 1974 to 1979. ASMG, a California medical professional corporation, created an irrevocable trust (Trust) to cover medical malpractice claims against its employees. ASMG on appeal disputes the Tax Court’s disallowance of its deductions for payments to the Trust and the court’s attribution of Trust income to it.

The well-reasoned opinion of the Tax Court, 85 T.C. 1031 (1985), gives the background of this case, and we do not…