Armantrout v. Commissioner
United States Tax Court
Hamlin, Inc., established and funded an educational trust arrangement providing for the payment of the education expenses of the children of its key employees. Expenses were paid by the trust, within certain designated limits, so long as they were incurred while the employee-parent was employed by Hamlin.
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Hamlin, Inc., established and funded an educational trust arrangement providing for the payment of the education expenses of the children of its key employees. Expenses were paid by the trust, within certain designated limits, so long as they were incurred while the employee-parent was employed by Hamlin. Held, the payments made by the trust are compensatory in character, includable in the employee-parent's income under sec. 83, I.R.C. 1954, when the trust pays the children's education expenses.
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioners as follows:
Petitioners Taxable year Docket No. Deficiency
Richard T. and Lois Armantrout. 1971 4344-75 $258.98
1972 4344-75 628.61
1973 4344-75 1,069.56
Francis H. and Elizabeth Pepper 1973 4460-75 922.17
Llewellyn G. and Ann H. Owens. 1971 4461-75 418.86
Upon joint motion of the parties, these cases were consolidated for trial, briefing, and opinion.
The sole issue for decision is whether petitioners should have included in income amounts paid to their respective children for education expenses by the…
2Cases cited16 opinions
- Williamson v. Lee Optical of Oklahoma, Inc.Supreme Court of the United States · 1955
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
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3Cited by18 opinions
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Richard T. Armantrout v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
- Knapp v. CommissionerUnited States Tax Court · 1988
- Warren G. Wheeler, Jr., Jean M. Wheeler, James J. McLaughlin Jr., and Mary K. McLaughlin v. The United StatesCourt of Appeals for the Federal Circuit · 1985
- Educo, Inc. v. Donald C. Alexander, Commissioner of Internal Revenue, DefendantsCourt of Appeals for the Seventh Circuit · 1977
13 more not listed; retrieve them via the Exa API.