Anesthesia Service Medical Group, Inc. v. Commissioner
United States Tax Court
ASMG, a medical professional corporation, established trust to provide protection for malpractice claims resulting from acts of ASMG's employees. Held, ASMG may not deduct contributions to trust. Held, further, trust was not a Voluntary Employees' Beneficiary Association. Held, further, trust is not taxable as an insurance company. Held, further, trust constituted a trust and not an association for tax purposes.
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ASMG, a medical professional corporation, established trust to provide protection for malpractice claims resulting from acts of ASMG's employees. Held, ASMG may not deduct contributions to trust. Held, further, trust was not a Voluntary Employees' Beneficiary Association. Held, further, trust is not taxable as an insurance company. Held, further, trust constituted a trust and not an association for tax purposes. Held, further, trust was a grantor trust whose income is taxable to ASMG.
1Opinion of the Court
Anesthesia Service Medical Group, Inc., Employee Protective Trust, San Diego Trust & Savings Bank, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent; Anesthesia Service Medical Group, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Anesthesia Service Medical Group, Inc. v. Commissioner
Docket Nos. 13935-83, 13936-83
United States Tax Court
85 T.C. 1031; 1985 U.S. Tax Ct. LEXIS 5; 85 T.C. No. 60;
December 24, 1985, Filed
Decision will be entered for the petitioner in docket No. 13935-83.
Decision will be entered for the respondent in docket No. 13936-83 in the…
2Cases cited43 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. CartwrightSupreme Court of the United States · 1973
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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