V.R. DeAngelis M.D.P.C. & R.T. Domingo M.D.P.C., V. R. DeAngelis M.D.P.C., Tax Matters Partner, et al. - Page 2
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John T. Morin and Ira B. Stechel, for petitioners.
Peter James Gavagan, Peggy J. Gartenbaum, and Thomas A.
Dombrowski, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: These cases are consolidated for purposes of
trial, briefing, and opinion. Each couple consists of a medical
doctor and his wife, and each doctor is the sole owner of an S
corporation that was a partner in the partnership V.R. DeAngelis
M.D.P.C. & R.T. Domingo M.D.P.C. (VRD/RTD). These cases concern
amounts paid in 1993 and 1994 by the S corporations to VRD/RTD
and its ensuing contributions of those amounts to the Severance
Trust Executive Program Multiple Employer Supplemental Benefit
Plan and Trust (STEP), a plan that was promoted to wealthy
professionals as a welfare benefits fund that was part of a 10-
or-more-employer plan described in section 419A(f)(6).2 STEP
used the contributions to purchase and pay the premiums on six
whole life insurance policies, five of which were each written
with respect to one or both spouses of each couple (with the
2 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code, Rule references
are to the Tax Court Rules of Practice and Procedure, and dollar
amounts are rounded to the dollar. We use the term “plan” for
convenience and do not suggest that any part of the STEP plan is
a bona fide plan for Federal income tax purposes.
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Last modified: March 27, 2008