Richardson v. Commissioner
United States Tax Court
A portion of the compensation otherwise receivable by petitioner from his employer was placed in a nonexempt trust for his benefit during 1969 and 1970. The trust agreement contained several provisions for the disposition of the trust funds in the event of the termination of petitioner's employment or his death and provided that he would render postretirement advice and counsel as required by his employer.
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A portion of the compensation otherwise receivable by petitioner from his employer was placed in a nonexempt trust for his benefit during 1969 and 1970. The trust agreement contained several provisions for the disposition of the trust funds in the event of the termination of petitioner's employment or his death and provided that he would render postretirement advice and counsel as required by his employer. Held, the entrusted funds deposited prior to Aug. 1, 1969, were nonforfeitable within the meaning of sec. 402(b), I.R.C. 1954, and the funds deposited after that date, when sec. 83, I.R.C.…
1Opinion of the Court
opinion
Featherston, Judge:
Respondent determined deficiencies in the amounts of $4,064.47 and $6,635.62 in petitioners’ Federal income tax for 1969 and 1970, respectively. The issues for decision are:(1) Whether funds placed in trust by petitioner Gale R. Richardson’s employer during 1969 and 1970 were properly taxable to petitioners during those years. The resolution of this issue, in turn, depends upon whether amounts transferred to the trust prior to August 1, 1969, were nonforfeitable within the meaning of section 402(b)1 and whether the amounts transferred to the trust after that date…
2Cases cited17 opinions
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- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Goodstein v. CommissionerUnited States Tax Court · 1958
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- Brodie v. CommissionerUnited States Tax Court · 1942
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