- 6 - spouse receives additional annuity payments after the participant's death. On the basis, in part, of Silberstein’s treatment of the plans as establishing subsidized joint and 100-percent survivor annuities for Rozenblatt and Jakubowicz and their spouses, petitioner made contributions to the plans in the total amounts of $227,646, $226,794, and $226,794, respectively, for each of the years 1987, 1988, and 1989. On its Federal income tax returns for years ending September 30, 1987, 1988, and 1989, petitioner claimed deductions under section 404 for the above total respective contributions to the plans in each year. For the year ending September 30, 1990, petitioner did not make any deductible contributions to the plans, and no deduction with regard thereto was claimed on petitioner's 1990 Federal income tax return. On audit of petitioner for 1987, 1988, and 1989, respondent treated Rozenblatt and Jakubowicz as receiving under the plans only a reduced joint and 100-percent survivor annuity. The present value of a reduced joint and 100-percent survivor annuity equals the present value of a single life annuity for the life of the participant (i.e., the value of a single life annuity for the life of the participant is spread over the actuarial life expectancies of the participant and the spouse).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011