Levine v. Commissioner
United States Tax Court
T, the majority stockholder and principal executive officer of X, a small family corporation, became ill in 1957 and received payments of $ 100 a week from X for a prolonged continuous period of over 5 or 6 years. X had no pension plan for employees and its other employee benefits were on a modest scale. It never gave sick pay to any other employees for any continuous period in excess of 2 weeks.
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T, the majority stockholder and principal executive officer of X, a small family corporation, became ill in 1957 and received payments of $ 100 a week from X for a prolonged continuous period of over 5 or 6 years. X had no pension plan for employees and its other employee benefits were on a modest scale. It never gave sick pay to any other employees for any continuous period in excess of 2 weeks. Held, the amounts received by T during 1960-1962 did not in fact represent bona fide sick pay for an employee but were paid to him because he was the majority stockholder; they are taxable to him as…
1Opinion of the Court
Samuel and Sophie Levine, Petitioners v. Commissioner of Internal Revenue, Respondent; Selco Supplies, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Levine v. Commissioner
Docket Nos. 6139-65, 6143-65
United States Tax Court
50 T.C. 422; 1968 U.S. Tax Ct. LEXIS 115;
June 4, 1968, Filed
Decisions will be entered under Rule 50.
T, the majority stockholder and principal executive officer of X, a small family corporation, became ill in 1957 and received payments of $ 100 a week from X for a prolonged continuous period of over 5 or 6 years. X had no pension plan for employees and its…
2Cases cited6 opinions
- Alan B. Larkin v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1968
- Lang v. CommissionerUnited States Tax Court · 1963
- Kaufman v. CommissionerUnited States Tax Court · 1961
- Larkin v. CommissionerUnited States Tax Court · 1967
- Estate of Leo P. Kaufman, Deceased, Alph C. Kaufman, and Estate of Ida W. Kaufman, Deceased, Alph C. Kaufman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
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