Commissioner of Internal Revenue v. Champion Spark Plug Company

This tax review has been heard and considered on the oral arguments of attorneys for the contending parties and on the appendix record in the case.

Briefly stated, the salient facts are that the board of directors of the respondent corporate taxpayer adopted a resolution in the latter part of 1953, directing the payment of $33,750 to a totally disabled salesman-employee (or, in the event of his death, to his widow) as a substitute for a policy of insurance on the salesman’s life which it had unsuccessfully attempted to secure under a pension plan; and the Tax Court considered that the…