SAUNDERS v. C.I.R.

No. 83-4284. Summary Calendar.

720 F.2d 871 (1983)

John C. SAUNDERS and Ellen W. Saunders, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

December 5, 1983.


Attorney(s) appearing for the Case

Bradford D. Corrigan, Jr., James A. Keller, Dallas, Tex., for petitioners-appellants.

John H. Menzel, Director, Tax Litigation Div., Michael L. Paup, Chief, Appellate Section, Glenn L. Archer, Jr., Asst. Atty. Gen., Thomas M. Preston, Ann B. Durney, Justice Dept., Tax Div., Washington, D.C., for respondent-appellee.

Before GEE, POLITZ and JOHNSON, Circuit Judges.


POLITZ, Circuit Judge:

This appeal presents the question whether funds distributed by an educational trust, established by a medical corporation-employer for the benefit of the children of its employees, were taxable as income to a physician-employee under the assignment of income doctrine. The Tax Court concluded that the income was taxable to the physician under either section 61 or 83 of the Internal Revenue Code of 1954, 26 U.S.C. §§ 61, 83. We agree...

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