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employees. We hold it may to the extent that the payments funded
term life insurance.
3. Whether Neonatology may deduct contributions made to its
plan to purchase life insurance for John Mall (Mr. Mall), who was
neither a Neonatology employee nor a person eligible to
participate in the Neonatology Plan. We hold it may not.
4. Whether Marlton may deduct contributions to its plan to
purchase insurance for its sole proprietor, Dr. Lo, who was
neither a Marlton employee nor a person eligible to participate
in the Marlton Plan. We hold it may not.
5. Whether section 264(a) precludes Marlton from deducting
contributions to its plan to purchase term life insurance for its
two employees. We hold it does.
6. Whether, in the case of Lakewood and Neonatology, the
disallowed contributions/payments are includable in the
employee/owners’ gross income.7 We hold they are.
7. Whether petitioners are liable for the accuracy-related
penalties for negligence or intentional disregard of rules or
regulations determined by respondent under section 6662(a). We
hold they are.
7 Petitioners concede that the contributions are includable
in the employees’ gross income to the extent that they provided
current-year life insurance protection.
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Last modified: May 25, 2011