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DE LOS SANTOS v. COMMISSIONER

Docket No. 5458-16.

156 T.C. 120 (2021)

156 T.C. No. 9

RUBEN DE LOS SANTOS AND MARTHA DE LOS SANTOS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 12, 2021.

Attorney(s) appearing for the Case

David M. Henderson , for petitioners.

David Conrad , David Weiner , and Mayer Y. Silber , for respondent.

OPINION

This case involves an S corporation that adopted an employee welfare benefit plan for petitioners and four rank-and-file employees. We have ruled that petitioners' participation in this plan constituted a compensatory "split-dollar" life insurance arrangement under section 1.61-22(b), Income Tax Regs., and that the...

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