Childs v. Commissioner
United States Tax Court
Ps are attorneys who received a structured settlement in payment of attorney's fees with respect to two related cases. In the first case, the settlement agreement provided that defendant's two insurance companies, Georgia Casualty and Stonewall, were to assign their obligation to a third insurance company, First Executive. First Executive purchased an annuity for each P from its subsidiary, Executive Life.
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Ps are attorneys who received a structured settlement in payment of attorney's fees with respect to two related cases. In the first case, the settlement agreement provided that defendant's two insurance companies, Georgia Casualty and Stonewall, were to assign their obligation to a third insurance company, First Executive. First Executive purchased an annuity for each P from its subsidiary, Executive Life. First Executive remained the owner of the annuity policies and maintained the right to change beneficiaries under the policies without the consent of Ps. Further, the parties to the…
1Opinion of the Court
Richard A. Childs, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Childs v. Commissioner
Docket Nos. 15639-92, 15640-92, 16256-92, 16257-92
United States Tax Court
103 T.C. 634; 1994 U.S. Tax Ct. LEXIS 80; 103 T.C. No. 36;
November 14, 1994, Filed
Decisions will be entered under Rule 155.
Ps are attorneys who received a structured settlement in payment of attorney's fees with respect to two related cases. In the first case, the settlement agreement provided that defendant's two insurance companies, Georgia Casualty and Stonewall, were to assign their obligation to a third…
2Cases cited18 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
- Sproull v. CommissionerUnited States Tax Court · 1951
- Amend v. CommissionerUnited States Tax Court · 1949
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