MacDonald v. Shaker Hts. Bd. of Income Tax Rev. (Slip Opinion)

{¶ 1} Before retiring as of December 31, 2006, William E. MacDonald III was an executive of the former National City Corporation in Cleveland. National City offered a “supplemental executive retirement plan” or “SERP” for its executives. Although for some tax purposes the SERP constituted an “unqualified deferred compensation plan,” MacDonald did not make contributions during his employment to fund the plan. As he neared retirement, MacDonald selected an option under that plan consisting not of a lump-sum payout but rather an annuity that would make periodic payments designed to replace a…