Grant-Jacoby, Inc. v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. LoBueSupreme Court of the United States · 1956
- United States v. BasyeSupreme Court of the United States · 1973
- Commissioner v. SmithSupreme Court of the United States · 1945
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3Cited by17 opinions
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- Ohio Teamsters Educational & Safety Training Trust Fund v. CommissionerUnited States Tax Court · 1981
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