Citrus Orthopedic Medical Group, Inc. v. Commissioner
United States Tax Court
Citrus, a corporation wholly owned by M and S, received virtually all of its income from medical service fees earned by M and S. Citrus set up an educational plan and trust to provide funds for the college education expenses of the children of M and S. Held, in view of the control retained by Citrus over the amounts of funds purportedly transferred to the trust in the taxable years 1974 and 1975, those amounts were not "paid or incurred" within the meaning of sec. 162(a)(1),…
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Citrus, a corporation wholly owned by M and S, received virtually all of its income from medical service fees earned by M and S. Citrus set up an educational plan and trust to provide funds for the college education expenses of the children of M and S. Held, in view of the control retained by Citrus over the amounts of funds purportedly transferred to the trust in the taxable years 1974 and 1975, those amounts were not "paid or incurred" within the meaning of sec. 162(a)(1), I.R.C. 1954, as compensation to M and S in those taxable years. Held, alternatively, if such amounts were paid or…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined deficiencies in the amounts of $3,520 and $10,423 in petitioner’s Federal income tax for the taxable years ended March 31, 1974, and March 31, 1975, respectively. The issues for decision are whether payments made by petitioner during those years to an educational benefit trust established for the children of certain of petitioner’s employees are deductible, and if so, in what taxable years.
The facts have been stipulated.
Citrus Orthopedic Medical Group, Inc. (hereinafter Citrus or petitioner), a California corporation, had its principal place of…
2Cases cited11 opinions
- United States v. BasyeSupreme Court of the United States · 1973
- Furman v. CommissionerUnited States Tax Court · 1966
- Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Sakol v. CommissionerUnited States Tax Court · 1977
- Estate of FerrallCalifornia Supreme Court · 1953
6 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
- Greensboro Pathology Associates, P.A. v. The United StatesCourt of Appeals for the Federal Circuit · 1982
- Grant-Jacoby, Inc. v. CommissionerUnited States Tax Court · 1980
- Moser v. CommissionerUnited States Tax Court · 1989
- Schneider v. CommissionerUnited States Tax Court · 1992
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