Rollert Residuary Trust v. Commissioner
United States Tax Court
1. Prior to his death on Nov. 27, 1969, decedent was an executive vice president of GM. Shortly before the date of death, GM had tentatively determined to issue bonuses for 1969 to a group of employees, including decedent. However, it was not until Mar. 2, 1970 -- more than 3 months after the date of death -- that the bonus was formally awarded to decedent.
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1. Prior to his death on Nov. 27, 1969, decedent was an executive vice president of GM. Shortly before the date of death, GM had tentatively determined to issue bonuses for 1969 to a group of employees, including decedent. However, it was not until Mar. 2, 1970 -- more than 3 months after the date of death -- that the bonus was formally awarded to decedent. The bonuses were paid under an established deferred compensation plan, with bonuses never having been denied to executive vice presidents and decedent's having received over $ 300,000 annually in bonuses during the years 1964 through 1968.…
1Opinion of the Court
OPINION
Whitaker, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes in the amounts of $83,795 for 1973; $68,686 for 1974; and $2,675 for 1975.
This case was submitted fully stipulated under Rule 122, Tax Court Rules of Practice and Procedure. The primary issues for decision are: (1) Whether rights to receive bonus payments under the General Motors bonus plan, which were attributable to an individual’s employment with General Motors before his death but which were not formally awarded until several months after his death, are rights to income in respect of a decedent;…
2Cases cited26 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Frentz v. CommissionerUnited States Tax Court · 1965
21 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Edward D. Rollert Residuary Trust, Genesee Merchants Bank and Trust Company, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- William Bryen Co. v. CommissionerUnited States Tax Court · 1987
- Kitch v. CommissionerUnited States Tax Court · 1995
43 more not listed; retrieve them via the Exa API.