Edward D. Rollert Residuary Trust v. Commissioner

80 T.C. 619 (1983)

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Edward D. Rollert Residuary Trust v. Commissioner

United States Tax Court
80 T.C. 619 (1983)

Facts

Edward D. Rollert was employed as an executive vice president at General Motors Corporation (GM) for several years until his death in late November 1969. In that role, he was eligible to participate in the company’s bonus programs. For every year from 1964 through 1968, Rollert received awards of over $300,000 under the program. In March 1970, following his death, Rollert was awarded a bonus of 1,786 shares of company stock and $285,763 in cash, reflecting his nearly 11-month employment in 1969. GM’s practice was always to award bonuses to executive vice presidents, and three weeks before Rollert’s death, GM had tentatively determined that it would do so again for 1969. GM also had a consistent practice of awarding benefits to individuals whose employment ceased during the bonus year, as long as they had completed at least two months of employment. The Edward D. Rollert Residuary Trust (plaintiff) petitioned the tax court for a determination of whether the bonus constituted income in respect of a decedent.

Rule of Law

Issue

Holding and Reasoning (Whitaker, J.)

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