Turnham v. Commissioner, No. 19-12875 (11th Cir. 2020)Annotate this Case
Appellants, a medical doctor and the subchapter S Corporation for which he works, filed suit against the IRS due to penalties it assessed against them for their failure to inform the IRS about questionable deductions the Corporation took for contributions it made for life insurance benefits. The district court granted summary judgment to the IRS.
The Eleventh Circuit affirmed the district court's decision determining that the IRS was correct to issue penalties based on the ground that appellants did not file the required notice. In this case, the multi-employer welfare benefit plan is at least substantially similar to the type of plans that the IRS has indicated do not qualify for the exemption from IRC 419 and the corresponding IRC 419A(f)(6) deduction. Therefore, the district court correctly decided to grant summary judgment to the IRS.