Neonatology Assocs., P.A. v. Comm'r
United States Tax Court
Certain insurance salesmen formed two purported voluntary employees' beneficiary associations (VEBA's) to generate commissions on their sales of life and other insurance products purchased through the VEBA's. Each employer/participant contributed to its own plan formed under the VEBA's, and each plan generally provided that a covered employee would receive current-year (term) life insurance on his or her life.
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Certain insurance salesmen formed two purported voluntary employees' beneficiary associations (VEBA's) to generate commissions on their sales of life and other insurance products purchased through the VEBA's. Each employer/participant contributed to its own plan formed under the VEBA's, and each plan generally provided that a covered employee would receive current-year (term) life insurance on his or her life. Premiums on the underlying insurance policies were substantially greater than the cost of term life insurance because they funded both the cost of term life insurance and credits which…
1Opinion of the Court
Laro, Judge:
The docketed cases, consolidated for purposes of trial, briefing, and opinion, represent three test cases selected by the parties to resolve their disagreements as to certain voluntary employees’ beneficiary association (VEBA) plans; namely, the Southern California Medical Profession Association VEBA (SC VEBA) and the New Jersey Medical Profession Association VEBA (NJ veba).2 The parties in 19 other cases pending before the Court have agreed to be bound by the decisions we render herein as to these VEBA issues.
Two of the test cases involve a corporate employer and one or more…
2Cases cited56 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Gallick v. Baltimore & Ohio RailroadSupreme Court of the United States · 1963
51 more not listed; retrieve them via the Exa API.
3Cited by422 opinions
- National Security Systems, Inc. v. IolaCourt of Appeals for the Third Circuit · 2012
- Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
- Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
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