Keller v. Commissioner
United States Tax Court
Petitioner, a pathologist, organized and operated a so-called one-man professional service corporation under the Oklahoma Professional Corporation Act. The corporation adopted, among other things, a defined benefit pension plan and a medical reimbursement plan. Petitioner and the corporation entered into an agreement for petitioner's services at the time of the organization of the corporation.
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Petitioner, a pathologist, organized and operated a so-called one-man professional service corporation under the Oklahoma Professional Corporation Act. The corporation adopted, among other things, a defined benefit pension plan and a medical reimbursement plan. Petitioner and the corporation entered into an agreement for petitioner's services at the time of the organization of the corporation. Held: Applying sec. 482, I.R.C. 1954, to the facts of this case, petitioner's total compensation (salary, pension plan contributions, and medical benefits) from the corporation was essentially…
1Opinion of the Court
Nims, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1974 and 1975 in the respective amounts of $25,375.46 and $34,195.77. The issue for decision is whether income attributable to petitioner Daniel F. Keller’s medical practice is taxable to him instead of his wholly owned professional corporation.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation and the exhibits attached thereto are incorporated herein by reference.
At the time the petition in this case was filed, petitioners resided in Oklahoma City, Okla.
Petitioner Daniel F. Keller…
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Whipple v. CommissionerSupreme Court of the United States · 1963
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3Cited by58 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Haag v. CommissionerUnited States Tax Court · 1987
- Johnson v. CommissionerUnited States Tax Court · 1982
- Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983
- Pacella v. CommissionerUnited States Tax Court · 1982
53 more not listed; retrieve them via the Exa API.