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SAUNDERS v. COMMISSIONER

Docket No. 14942-79.

45 T.C.M. 82 (1982)

T.C. Memo. 1982-655

John C. Saunders and Ellen W. Saunders v. Commissioner.

United States Tax Court.

Filed November 15, 1982.

Attorney(s) appearing for the Case

Robert C. Taylor and Bradford D. Corrigan, Jr., 2700 Republic Nat'l Bank Tower, Dallas, Tex., for the petitioners. Helen T. Repsis, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the taxable years 1976 and 1977 in the amounts of $2,959.99 and $5,359.62, respectively.

The sole issue for decision is whether certain funds distributed to petitioners' children by an educational benefit trust established by John C. Saunders' professional corporation represented compensation taxable to petitioners under the assignment...

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