Legal Opinion

Wilson v. Commissioner

United States Tax Court

Decided November 6, 1962No. Docket No. 92910Published

In 1957 petitioner Charles Wilson retired from the employ of Triad Oil Company. Upon his retirement, Triad purchased a single-premium, no-refund annuity for petitioner. The annuity provided for payments of $ 50 per month to petitioner for his life. The annuity provided for assignment.

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In 1957 petitioner Charles Wilson retired from the employ of Triad Oil Company. Upon his retirement, Triad purchased a single-premium, no-refund annuity for petitioner. The annuity provided for payments of $ 50 per month to petitioner for his life. The annuity provided for assignment. Held: 1. Petitioner's rights under the annuity contract were nonforfeitable within the meaning of section 403(c), I.R.C. 1954. 2. On the facts presented, petitioner has not demonstrated that as applied to him section 403(c), I.R.C. 1954, is unconstitutional. 3. The amount paid by petitioner's employer for the…

1Opinion of the Court

Charles Wilson and Goldie Mae Wilson, Petitioners, v. Commissioner of Internal Revenue, Respondent

Wilson v. Commissioner

Docket No. 92910

United States Tax Court

39 T.C. 362; 1962 U.S. Tax Ct. LEXIS 32;

November 6, 1962, Filed

Decision will be entered for the respondent.

In 1957 petitioner Charles Wilson retired from the employ of Triad Oil Company. Upon his retirement, Triad purchased a single-premium, no-refund annuity for petitioner. The annuity provided for payments of $ 50 per month to petitioner for his life. The annuity provided for assignment. Held:

1. Petitioner's rights under the annuity…

2Cases cited19 opinions

  1. Heiner v. DonnanSupreme Court of the United States · 1932
  2. Helvering v. WinmillSupreme Court of the United States · 1938
  3. Commissioner v. SmithSupreme Court of the United States · 1945
  4. Monamotor Oil Co. v. JohnsonSupreme Court of the United States · 1934
  5. Brodie v. CommissionerUnited States Tax Court · 1942

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