Whitcomb v. Commissioner
United States Tax Court
T retired in 1971 from his position as president of C, a corporation controlled by T and his wife and wholly owned within T's family. After his retirement, T continued to provide services to C and its subsidiaries during part of the year, but he was not formally employed by the company, and he did not receive any compensation designated as salary for his services.
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T retired in 1971 from his position as president of C, a corporation controlled by T and his wife and wholly owned within T's family. After his retirement, T continued to provide services to C and its subsidiaries during part of the year, but he was not formally employed by the company, and he did not receive any compensation designated as salary for his services. From 1968 through the years in question (1974 and 1975), C maintained a policy of group-term life insurance for all of its employees. In response to T's estate planning requirements, C purchased in 1973 a separate $ 1 million "whole…
1Opinion of the Court
Arthur K. Whitcomb and Lena R. Whitcomb, Petitioners v. Commissioner of Internal Revenue, Respondent; Arthur Whitcomb, Inc., and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Whitcomb v. Commissioner
Docket Nos. 3360-79, 3361-79
United States Tax Court
81 T.C. 505; 1983 U.S. Tax Ct. LEXIS 35; 81 T.C. No. 30;
September 21, 1983, Filed
Decisions will be entered for the respondent.
T retired in 1971 from his position as president of C, a corporation controlled by T and his wife and wholly owned within T's family. After his retirement, T continued to provide services to C and…
2Cases cited6 opinions
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- D'Angelo Assoc., Inc. v. CommissionerUnited States Tax Court · 1978
- Whitcomb v. CommissionerUnited States Tax Court · 1983
- Enright v. CommissionerUnited States Tax Court · 1971
- Towne v. CommissionerUnited States Tax Court · 1982
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