Whitcomb v. Commissioner
United States Tax Court
T retired in 1971 from his position as president of C, a corporation controlled by T and his wife and wholly owned within T's family. After his retirement, T continued to provide services to C and its subsidiaries during part of the year, but he was not formally employed by the company, and he did not receive any compensation designated as salary for his services.
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T retired in 1971 from his position as president of C, a corporation controlled by T and his wife and wholly owned within T's family. After his retirement, T continued to provide services to C and its subsidiaries during part of the year, but he was not formally employed by the company, and he did not receive any compensation designated as salary for his services. From 1968 through the years in question (1974 and 1975), C maintained a policy of group-term life insurance for all of its employees. In response to T's estate planning requirements, C purchased in 1973 a separate $ 1 million "whole…
1Opinion of the Court
Raum, Judge:
The Commissioner determined income tax deficiencies as follows:
Year Deficiency
1974 1975 $2,624.00 18,242.00 Arthur Whitcomb, Inc., and Subsidiaries
1974 1975 2,877.52 17,115.55 Arthur K. and Lena R. Whitcomb
After concessions, the only issues remaining for decision are whether Arthur Whitcomb, Inc., and Subsidiaries may take deductions for, and whether Arthur K. and Lena R. Whitcomb must include in income, premiums paid by Arthur Whitcomb, Inc., and Subsidiaries for 1974 and 1975 on a $1 million term insurance policy on the life of Arthur K. Whitcomb, which policy was purportedly…
2Cases cited5 opinions
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