Childs v. Commissioner
United States Tax Court
Ps are attorneys who received a structured settlement in payment of attorney's fees with respect to two related cases. In the first case, the settlement agreement provided that defendant's two insurance companies, Georgia Casualty and Stonewall, were to assign their obligation to a third insurance company, First Executive. First Executive purchased an annuity for each P from its subsidiary, Executive Life.
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Ps are attorneys who received a structured settlement in payment of attorney's fees with respect to two related cases. In the first case, the settlement agreement provided that defendant's two insurance companies, Georgia Casualty and Stonewall, were to assign their obligation to a third insurance company, First Executive. First Executive purchased an annuity for each P from its subsidiary, Executive Life. First Executive remained the owner of the annuity policies and maintained the right to change beneficiaries under the policies without the consent of Ps. Further, the parties to the…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners Richard A. Childs’ and Mimi P. Childs’ income tax for the taxable years 1986 and 1987 in the amounts of $37,176.42 and $34,792.85, respectively, and additions to tax under section 66612 for the taxable years 1986 and 1987 in the amounts of $9,294 and $8,698, respectively. Respondent determined deficiencies in the income tax of petitioners John C. Swearingen, Jr., and Suzanne N. Swearingen for the taxable years 1986 and 1987 in the amounts of $40,977.76 and $44,952, respectively, and additions to tax under section 6661 for the…
2Cases cited17 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
- Sproull v. CommissionerUnited States Tax Court · 1951
- Amend v. CommissionerUnited States Tax Court · 1949
12 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- In Re: OrsoCourt of Appeals for the Fifth Circuit · 2000
- Jombo v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2005
- Kadillak v. Comm'rUnited States Tax Court · 2006
- Jombo v. Comm'rUnited States Tax Court · 2002
- Sainte Claire Corp. v. CommissionerUnited States Tax Court · 1997
7 more not listed; retrieve them via the Exa API.