John C. Saunders and Ellen W. Saunders v. Commissioner of Internal Revenue

POLITZ, Circuit Judge:

This appeal presents the question whether funds distributed by an educational trust, established by a medical corporation-employer for the benefit of the children of its employees, were taxable as income to a physician-employee under the assignment of income doctrine. The Tax Court concluded that the income was taxable to the physician under either section 61 or 83 of the Internal Revenue Code of 1954, 26 U.S.C. §§ 61, 83. We agree and affirm.

Facts

Dr. John C. Saunders 1 incorporated John C. Saunders, M.D. and Associates, a professional association, for the purpose of…