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 4
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income received by each doctor from his S corporation. Second,
respondent determined that each doctor received income under
section 61(a) in the amount of the life insurance premiums that
were paid by his S corporation on his behalf.
We decide whether the S corporations and VRD/RTD were
entitled to deduct the payments related to the STEP plan as
ordinary and necessary business expenses under section 162(a).
We hold they were not to the extent that the payments related to
the life insurance written on a life of someone other than Ms.
Quinn.3 We also decide whether each doctor realized income in
the amount of the life insurance premiums that were paid by his S
corporation on his behalf. We hold he did not.
FINDINGS OF FACT
Some facts were stipulated. The stipulated facts and the
exhibits submitted therewith are incorporated herein by this
reference. We find the stipulated facts accordingly. VRD/RTD
had a legal address in the State of New York when its petition
was filed. The individual petitioners resided in the State of
New York when their petitions were filed.
3 We understand respondent to have conceded that the
payments are deductible to the extent they relate to the
insurance written on the life of Ms. Quinn.
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Last modified: March 27, 2008