Drysdale v. Commissioner
United States Tax Court
A corporation made monthly payments to a trustee for the principal petitioner's exclusive benefit in consideration for services rendered by him. The trustee was to distribute the payments to petitioner upon his retirement from full-time employment or attaining 65 years of age, whichever came first. Petitioner's right to receive the payments was nonforfeitable.
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A corporation made monthly payments to a trustee for the principal petitioner's exclusive benefit in consideration for services rendered by him. The trustee was to distribute the payments to petitioner upon his retirement from full-time employment or attaining 65 years of age, whichever came first. Petitioner's right to receive the payments was nonforfeitable. The corporation was willing and able to make the payments directly to petitioner instead of to a trustee, but the trust arrangement for deferring petitioner's receipt of the payments was created at petitioner's suggestion. Respondent…
1Opinion of the Court
BRUCE, Judge:
This proceeding involves deficiencies in income tax for the calendar years 1954 and 1955 in the respective amounts of $11,163.14 and $11,879.13. The only issue is whether the sums of $16,500 and $18,000 paid by Briggs Manufacturing Company to the Detroit. Trust Company, trustee, in 1954 and 1955, respectively, as compensation to the principal petitioner under an amended employment contract constituted taxable income in the years paid.
FINDINGS OF FACT.
The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
At all times pertinent petitioners…
2Cases cited6 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
- Sproull v. CommissionerUnited States Tax Court · 1951
- Loose v. United StatesCourt of Appeals for the Eighth Circuit · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Frost v. CommissionerUnited States Tax Court · 1969
- Anastasio v. CommissionerUnited States Tax Court · 1977
- Zeltzerman v. CommissionerUnited States Tax Court · 1960
- Willits v. CommissionerUnited States Tax Court · 1968
- Teget v. United StatesDistrict Court, D. South Dakota · 1976
9 more not listed; retrieve them via the Exa API.