Neonatology Associates, P.A. v. Commissioner

115 T.C. No. 5

UNITED STATES TAX COURT NEONATOLOGY ASSOCIATES, P.A., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1201-97, 1208-97, Filed July 31, 2000. 2795-97, 2981-97, 2985-97, 2994-97, 2995-97, 4572-97. 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…