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
Cohen, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Petitioner Year Deficiency
Anesthesia Service Medical 1974 $4,155
Group, Inc. (ASMG) 1976 1,411
Docket No. 13936-83 1977 207,313
1978 264,619
1979 144,762
Anesthesia Service Medical 1977 332,602
Group, Inc. Employee Protective Trust (trust) 1978 1979 358,606 289,720
Docket No. 13935-83
By amended answer respondent determined increased deficiencies in tax of petitioner ASMG of $300 for 1978 and $27,601 for 1979. The issues for decision are as follows: (1) Whether petitioner ASMG may deduct contributions…
2Cases cited42 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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3Cited by26 opinions
- Lima Surgical Associates, Inc. Voluntary Employees' Beneficiary Ass'n Plan Trust v. United StatesUnited States Court of Claims · 1990
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Johnson v. CommissionerUnited States Tax Court · 1997
- Humana, Inc. v. CommissionerUnited States Tax Court · 1987
- Anesthesia Service Medical Group, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
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