Centre v. Commissioner
United States Tax Court
An employment agreement required the employer to maintain insurance policies on the employee as a means of funding the employer's obligation to make deferred compensation payments. The employer was the owner and beneficiary of the policies; the employee could obtain them only if the terminated his employment prior to his normal retirement age without any substantial willful breach of the employment agreement.
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An employment agreement required the employer to maintain insurance policies on the employee as a means of funding the employer's obligation to make deferred compensation payments. The employer was the owner and beneficiary of the policies; the employee could obtain them only if the terminated his employment prior to his normal retirement age without any substantial willful breach of the employment agreement. Held, the employee realized taxable income when the policies were transferred to him following termination of his employment rather than when the premiums thereon were paid.
1Opinion of the Court
David Centre and Marian Centre, Petitioners v. Commissioner of Internal Revenue, Respondent
Centre v. Commissioner
Docket No. 853-68
United States Tax Court
55 T.C. 16; 1970 U.S. Tax Ct. LEXIS 56;
October 7, 1970, Filed
Decision will be entered for the respondent.
An employment agreement required the employer to maintain insurance policies on the employee as a means of funding the employer's obligation to make deferred compensation payments. The employer was the owner and beneficiary of the policies; the employee could obtain them only if the terminated his employment prior to his normal retirement…
2Cases cited11 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Brodie v. CommissionerUnited States Tax Court · 1942
- Sproull v. CommissionerUnited States Tax Court · 1951
- Casale v. CommissionerUnited States Tax Court · 1956
6 more not listed; retrieve them via the Exa API.