Brodie v. Commissioner
United States Tax Court
The board of directors of a corporation, of which petitioners were employees, had in a prior year established a five-year plan for additional remuneration to certain executives and employees of the company. The plan provided that at the end of each fiscal year the president of the company should determine the persons to receive additional compensation out of the fund established and the amount to be paid to each.
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The board of directors of a corporation, of which petitioners were employees, had in a prior year established a five-year plan for additional remuneration to certain executives and employees of the company. The plan provided that at the end of each fiscal year the president of the company should determine the persons to receive additional compensation out of the fund established and the amount to be paid to each. In the taxable year the president of the company directed the purchase, out of the fund, of certain paid-up retirement annuity contracts with death benefit clauses for petitioners…
1Opinion of the Court
OPINION.
Black, Judge:
These proceedings ha-ve been consolidated. The issue in each proceeding is identical and the facts are the same except as to the names of the different individuals involved, their positions and length of service with the company, and the amounts of alleged income involved. The same question as to the admissibility of certain of the stipulated facts was raised by these petitioners at the hearing as was raised in Richard R. Deupree, I. T. C. 118.
As in that proceeding, the presiding Member reserved his ruling upon the admissibility of such evidence. Inasmuch as the question…
2Cited by82 opinions
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
- Sibla v. CommissionerUnited States Tax Court · 1977
- Sproull v. CommissionerUnited States Tax Court · 1951
- Taylor v. CommissionerUnited States Tax Court · 1943
- Lincoln Electric Co. v. CommissionerUnited States Tax Court · 1946
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