Legal Opinion

Haugen v. Commissioner

United States Tax Court

Decided November 18, 1971No. Docket No. 3604-69Unpublished

Petitioner was director of the pathology department of Holy Cross Hospital, Fort Lauderdale, Florida. The hospital withheld an amount from the compensation earned by the petitioner, and paid it to Franklin Life Insurance Co. to acquire a nonforfeitable annuity for petitioner. Held, petitioner was an employee within the context of sec. 403(b), I.R.C. 1954, thereby permitting exclusion of the amounts paid for the annuity from petitioner's income.

1Opinion of the Court

Roger K. Haugen and Hope L. Haugen v. Commissioner.

Haugen v. Commissioner

Docket No. 3604-69.

United States Tax Court

T.C. Memo 1971-294; 1971 Tax Ct. Memo LEXIS 38; 30 T.C.M. (CCH) 1247; T.C.M. (RIA) 71294;

November 18, 1971, Filed

Petitioner was director of the pathology department of Holy Cross Hospital, Fort Lauderdale, Florida. The hospital withheld an amount from the compensation earned by the petitioner, and paid it to Franklin Life Insurance Co. to acquire a nonforfeitable annuity for petitioner. Held, petitioner was an employee within the context of sec. 403(b), I.R.C. 1954, thereby…

2Cases cited6 opinions

  1. Hand v. CommissionerUnited States Tax Court · 1951
  2. Manouchehr and Lila M. Azad v. United StatesCourt of Appeals for the Eighth Circuit · 1968
  3. Ellison v. CommissionerUnited States Tax Court · 1970
  4. Zeltzerman v. CommissionerUnited States Tax Court · 1960
  5. Maxwell B. Llewellyn and Gertrude Llewellyn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961

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