Legal Opinion
George Sercl, Jr., and Maryanne Sercl v. United States
Court of Appeals for the Eighth Circuit
Decided August 9, 1982No. 82-1081PublishedCited by 10 opinions
1Opinion of the Court
BRIGHT, Circuit Judge.
The United States appeals from the district court’s grant of summary judgment in favor of taxpayers George Sercl, Jr. (Sercl, Jr.), and his wife, Maryanne. The district court held that Sercl, Jr.’s, “split dollar” insurance agreement with his company did not constitute taxable income to him because the agreement fell within the “grandfather clause” in Rev.Rul. 64-328, 1964-2 Cum.Bull. 11. See Sercl v. United States, 538 F.Supp. 460 (D.S.D.1981). We reverse.
I. Background.
On November 4, 1964, Sunshine Food Markets, Inc. (Sunshine), and George Sercl, Sr. (Sercl, Sr.), then…
2Cases cited6 opinions
- Dean v. CommissionerUnited States Tax Court · 1961
- Greenspun v. CommissionerUnited States Tax Court · 1979
- Albert Suttle and Grace E. Suttle v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1980
- Colin F. And Eleanor M. Beaton v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1981
- William G. And Martha C. Martin v. Commissioner of Internal Revenue, Joseph and Evelyn Creel v. Commissioner of Internal Revenue, Jonnie Parkinson v. Commissioner of Internal Revenue, Max Zager and Goldie R. Zager v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
- Mary Tataranowicz v. Louis W. Sullivan, M.D., in His Official Capacity as Secretary, Department of Health and Human ServicesCourt of Appeals for the D.C. Circuit · 1992
- Estate of Gerson v. Comm'rUnited States Tax Court · 2006
- Simpson v. United StatesDistrict Court, W.D. Missouri · 1998
- Bachler v. United StatesDistrict Court, N.D. California · 2000
5 more not listed; retrieve them via the Exa API.