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Income Tax Keyed to Bankman
Minor v. United States
Citation:
772 F.2d 1472 (9th Cir. 1985)Facts
Respondent was a physician who entered into an agreement with Snohomish County Physicians Corporation whereby he agreed to perform medical services for the Snohomish Physicians’ patients and be paid by a set fee schedule. Respondent also enrolled in Snohomish Physicians’ deferred compensation plan where he elected to defer first 50% then later 90% of his income. The plan was administered through a trust where Snohomish Physicians was the settlor and beneficiary, and Respondent, along with two other physicians, was a trustee. The trustees purchased retirement annuity policies with benefits that would become payable upon retirement, death, disability, or if the physician were to leave the Snohomish Physicians service area to practice elsewhere. The plan also required that the physicians agree to limit their practice after retirement and not compete against Snohomish Physicians. In 1970, 1971, and 1973, Respondent reported only 10% of his scheduled fees as taxable income as the remainder was transferred to the deferred compensation plan. The IRS asserted that the remaining 90% that was diverted to the trust should be included as taxable income under the economic benefit doctrine.
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