UNITED STATES TAX COURT OUR COUNTRY HOME ENTERPRISES, INC., ET AL.,
Petitioners v. 1 COMMISSIONER OF INTERNAL REVENUE,
Respondent Docket Nos. 25764-10, 25765-10, Filed July 13, 2015. 11520-11, 11521-11, 12744-11, 12745-11, 12746-11.
The death benefit that SP agrees to pay as to a participating employee is the face amount of an insurance policy that SP purchases on the employee’s life. The employer effectively pays the premiums on the insurance policy through its payments to SP, and the insurance policy usually has a cash value component that increases annually. SP’s payment of any nondeath benefit as to an employee is generally limited to the cash value of the insurance policy related to that employee. An employer may terminate its participation in SP and cause each of its employees to be fully vested in his or her policy (including its cash value). A participating employee, upon retiring, may take his or her insurance policy in satisfaction of any postretirement death benefit payable as to the employee.
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