Jacuzzi v. Commissioner
United States Tax Court
Petitioner's employer unconditionally paid certain amounts to a trustee as compensation for services previously rendered to it by the petitioner. At the end of the trust term the trustee was to pay the entire entrusted funds to petitioner or if he were not alive to certain named members of his family. Held, the petitioner realized income when his employer placed funds in trust for petitioner's benefit.
1Opinion of the Court
Wiles, Judge:*
Respondent has determined the following deficiencies in petitioners’ income tax:
Tear Deficiency
3.959 _$964,649.14
1960 _ 72,762.55
The only issue remaining for our decision is whether petitioner, Can-dido Jacuzzi, realized taxable income in 1960 when his employer paid to a trust for his benefit certain amounts representing salary earned by him during 1959 and 1960 and interest thereon.
FINDINGS OF FACT
Some of the fact have been stipulated and are found accordingly.
Petitioners are Candido Jacuzzi (hereinafter referred to as petitioner) and Inez Jacuzzi, husband and wife, who resided…
2Cases cited8 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Commissioner v. SmithSupreme Court of the United States · 1945
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
3 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Stiles v. CommissionerUnited States Tax Court · 1978
- Watson v. CommissionerUnited States Tax Court · 1978
- Anastasio v. CommissionerUnited States Tax Court · 1977
- Richardson v. CommissionerUnited States Tax Court · 1975
- Bizzack Bros. Constr. Corp. v. CommissionerUnited States Tax Court · 1980
7 more not listed; retrieve them via the Exa API.