Legal Opinion

Grant-Jacoby, Inc. v. Commissioner

United States Tax Court

Decided January 16, 1980No. Docket Nos. 1159-77, 7236-77, 7237-77, 7238-77, 7239-77PublishedCited by 17 opinions

C, a corporation, adopted an educational benefit plan, which provided for the payment of certain college expenses of the children of its key employees, and it made contributions under the plan during the years in issue. However, payments to the children of an eligible employee would cease upon the termination of his employment with C in most instances. Ps were employees whose children received disbursements under the plan during the years in issue.

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C, a corporation, adopted an educational benefit plan, which provided for the payment of certain college expenses of the children of its key employees, and it made contributions under the plan during the years in issue. However, payments to the children of an eligible employee would cease upon the termination of his employment with C in most instances. Ps were employees whose children received disbursements under the plan during the years in issue. Held, the distributions from the plan to the children of Ps during the years in issue constituted deferred compensation to Ps and are includable…

1Opinion of the Court

Simpson, Judge:

The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes:

Petitioners Taocable year ending Deficiency

Grant-Jacoby, Inc. 8/31/73 8/31/74 $5,618 8,542

Charles A. Norris. 12/31/73 12/31/74 480 1,477

Robert Krewer and Dolores Krewer_ 12/31/73 12/31/74 405 927

Robert Lavender and Sharon Lavender. 12/31/74 370

Robert L. Flink and Doris Flink. 12/31/73 12/31/74 1,765 873

The issues for decision are: (1) Whether distributions under an employer-sponsored plan providing for payment of the educational expenses of children of certain key employees represent…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Commissioner v. LoBueSupreme Court of the United States · 1956
  4. United States v. BasyeSupreme Court of the United States · 1973
  5. Commissioner v. SmithSupreme Court of the United States · 1945

9 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Booth v. CommissionerUnited States Tax Court · 1997
  2. Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
  3. Greensboro Pathology Associates, P.A. v. The United StatesCourt of Appeals for the Federal Circuit · 1982
  4. Knapp v. CommissionerUnited States Tax Court · 1988
  5. Ohio Teamsters Educational & Safety Training Trust Fund v. CommissionerUnited States Tax Court · 1981

12 more not listed; retrieve them via the Exa API.

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