Legal Opinion

Keller v. Commissioner

United States Tax Court

Decided October 29, 1981No. Docket No. 7128-79Published

Petitioner, a pathologist, organized and operated a so-called one-man professional service corporation under the Oklahoma Professional Corporation Act. The corporation adopted, among other things, a defined benefit pension plan and a medical reimbursement plan. Petitioner and the corporation entered into an agreement for petitioner's services at the time of the organization of the corporation.

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Petitioner, a pathologist, organized and operated a so-called one-man professional service corporation under the Oklahoma Professional Corporation Act. The corporation adopted, among other things, a defined benefit pension plan and a medical reimbursement plan. Petitioner and the corporation entered into an agreement for petitioner's services at the time of the organization of the corporation. Held: Applying sec. 482, I.R.C. 1954, to the facts of this case, petitioner's total compensation (salary, pension plan contributions, and medical benefits) from the corporation was essentially…

1Opinion of the Court

Daniel F. Keller and Marilyn F. Keller, Petitioners v. Commissioner of Internal Revenue, Respondent

Keller v. Commissioner

Docket No. 7128-79

United States Tax Court

77 T.C. 1014; 1981 U.S. Tax Ct. LEXIS 37;

October 29, 1981, Filed

Decision will be entered under Rule 155.

Petitioner, a pathologist, organized and operated a so-called one-man professional service corporation under the Oklahoma Professional Corporation Act. The corporation adopted, among other things, a defined benefit pension plan and a medical reimbursement plan. Petitioner and the corporation entered into an agreement for…

Also in this document: Dissent.

2Cases cited38 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  4. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  5. Dobson v. CommissionerSupreme Court of the United States · 1944

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