Estate of Rosenberg v. Commissioner
United States Tax Court
1. Decedent participated in a retirement plan of his employer pursuant to which he had an option, among others, to provide for a combination of retirement income for himself and death benefits for any designated survivor or survivors. At his retirement in 1974, the decedent set aside certain lump sums to be paid to specified beneficiaries at his death, thus reducing the amount of his pension actuarially computed.
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1. Decedent participated in a retirement plan of his employer pursuant to which he had an option, among others, to provide for a combination of retirement income for himself and death benefits for any designated survivor or survivors. At his retirement in 1974, the decedent set aside certain lump sums to be paid to specified beneficiaries at his death, thus reducing the amount of his pension actuarially computed. He died in 1980. One such lump sum ($ 25,000) was thus paid to his son, Peter. The son reported that amount as capital gain in his own income tax return, as permitted by sec.…
1Opinion of the Court
Estate of Frederick Rosenberg, Deceased, Peter D. Rosenberg, Coexecutor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Rosenberg v. Commissioner
Docket No. 20654-84
United States Tax Court
86 T.C. 980; 1986 U.S. Tax Ct. LEXIS 108; 86 T.C. No. 60; 7 Employee Benefits Cas. (BNA) 1649;
May 19, 1986, Filed
Decision will be entered for the respondent.
1. Decedent participated in a retirement plan of his employer pursuant to which he had an option, among others, to provide for a combination of retirement income for himself and death benefits for any designated survivor or survivors.…
2Cases cited80 opinions
- Dandridge v. WilliamsSupreme Court of the United States · 1970
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- Weinberger v. SalfiSupreme Court of the United States · 1975
- Duke Power Co. v. Carolina Environmental Study Group, Inc.Supreme Court of the United States · 1978
- Lindsley v. Natural Carbonic Gas Co.Supreme Court of the United States · 1911
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