Herman v. Commissioner
United States Tax Court
Due to the high cost and unavailability of medical malpractice insurance, a physician-owned insurance company known as the Medical Inter-Insurance Exchange of New Jersey (Exchange) was formed in 1976. In order to provide a surplus of funds, physicians or their professional corporations (P.C.'s) provided initial funding. A subordinated loan certificate (SLC) was issued by the Exchange in the name of individual physicians in return for these payments.
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Due to the high cost and unavailability of medical malpractice insurance, a physician-owned insurance company known as the Medical Inter-Insurance Exchange of New Jersey (Exchange) was formed in 1976. In order to provide a surplus of funds, physicians or their professional corporations (P.C.'s) provided initial funding. A subordinated loan certificate (SLC) was issued by the Exchange in the name of individual physicians in return for these payments. The SLC would be redeemed by the Exchange when the physician ceased practicing medicine in New Jersey. Where a P.C. paid for the SLC on behalf of…
1Opinion of the Court
Panuthos, Special Trial Judge:
These consolidated cases were heard pursuant to the provisions of section 7456(d)2 and General Order No. 8 of this Court, 81 T.C. XXIII (1983).
Respondent issued statutory notices of deficiency in these consolidated cases which determined deficiencies in petitioners’ 1977 Federal income taxes as follows:
Docket No. Deficiency
344-82. $1,423.01
345-82 . 3,979.23
347-82. 1,385.95
450-82. 1,494.66
709-82. 4,648.57
715-823 . 2,786.19
746-82 . 1,325.50
Docket No. Deficiency
751-82. $2,954.00
1753-824 . 529.80
2019-82. 769.54
2597-82. 1,388.36
9154-82. 4,795.00
9161-82. 2,494.00
14689-8…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
14 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Brizell v. CommissionerUnited States Tax Court · 1989
- T.J. ENTERPRISES v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1993
- HAN v. COMMISSIONERUnited States Tax Court · 2002
- Rhoads v. CommissionerUnited States Tax Court · 1987
- Spill v. CommissionerUnited States Tax Court · 1989
9 more not listed; retrieve them via the Exa API.