Estate of Silverman v. Commissioner
United States Tax Court
Decedent was a participant in his corporate employer's employees' pension plan, which plan qualified under sec. 401(a), I.R.C. 1954. This plan provided for a monthly annuity to participants to commence in all events when the participant reached 65. Decedent was not a stockholder of his corporate employer or a member of the pension committee. When decedent terminated his employment prior to reaching 65, his five annuity contracts were assigned absolutely to him.
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Decedent was a participant in his corporate employer's employees' pension plan, which plan qualified under sec. 401(a), I.R.C. 1954. This plan provided for a monthly annuity to participants to commence in all events when the participant reached 65. Decedent was not a stockholder of his corporate employer or a member of the pension committee. When decedent terminated his employment prior to reaching 65, his five annuity contracts were assigned absolutely to him. He surrendered three of these contracts for their cash surrender value and had borrowed prior to his death on the security of the…
1Opinion of the Court
Estate of Max Silverman, Deceased, Blanche S. Silverman, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Silverman v. Commissioner
Docket No. 2364-71
United States Tax Court
61 T.C. 605; 1974 U.S. Tax Ct. LEXIS 156; 61 T.C. No. 65;
February 4, 1974, Filed
Decision will be entered for the respondent.
Decedent was a participant in his corporate employer's employees' pension plan, which plan qualified under sec. 401(a), I.R.C. 1954. This plan provided for a monthly annuity to participants to commence in all events when the participant reached 65. Decedent was not a…
Also in this document: Concurrence · Tannenwald; Concurrence · Hall.
2Cases cited12 opinions
- Anderson v. HelveringSupreme Court of the United States · 1940
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- Powell v. RothensiesCourt of Appeals for the Third Circuit · 1950
- Russell v. CommissionerUnited States Tax Court · 1966
- Albright v. CommissionerUnited States Tax Court · 1964
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