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(except to the extent they relate to payments of premiums on the
Ms. Quinn policy as discussed supra note 3). Accord Neonatology
Associates, P.A. v. Commissioner, 115 T.C. 43 (2000).
Consequently, we hold that those amounts are not deductible under
section 162(a) by either the PCs or VRD/RTD.22
B. Inclusion in Income
Respondent determined that the amounts of the life insurance
premiums that were paid by each doctor’s PC on his behalf are
includable in the doctor’s gross income under section 61(a) as
“accessions to wealth, clearly realized, and over which the
taxpayers have complete dominion.” See Commissioner v. Glenshaw
Glass Co., 348 U.S. 426, 431 (1955). We disagree that those
amounts are includable in the doctors’ gross income. While the
payments of the premiums were indeed accessions to the doctors’
wealth, our decision on this issue does not rest simply on that
finding. Instead, our decision turns on our finding that the
doctors’ PCs were S corporations and that the payment of the
premiums by the PCs was essentially a distribution to the doctors
of corporate profits rather than a payment that the PCs made to
the doctors with a compensatory intent. See Neonatology
22 Although the PCs may arguably be entitled to deduct the
costs of the current life insurance protection purchased through
the STEP plan, see Neonatology Associates, P.A. v. Commissioner,
115 T.C. 43 (2000), petitioners have not requested any such
deductions, and the record does not allow the Court to find the
amounts of any such deductions.
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