Michael P. Schwab and Kathryn J. Kleinman v. Commissioner

136 T.C. No. 6, 136 T.C. 120, 2011 U.S. Tax Ct. LEXIS 7
CourtUnited States Tax Court
DecidedFebruary 7, 2011
DocketDocket 10525-07
StatusUnknown

This text of 136 T.C. No. 6 (Michael P. Schwab and Kathryn J. Kleinman v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael P. Schwab and Kathryn J. Kleinman v. Commissioner, 136 T.C. No. 6, 136 T.C. 120, 2011 U.S. Tax Ct. LEXIS 7 (tax 2011).

Opinion

OPINION

Holmes, Judge:

When a company winds up an employee-benefit plan and distributes its assets, section 402(b) 1 says an employee receiving his share of those assets has to pay tax on “the amount actually distributed.” Michael Schwab and his wife Kathryn Kleinman both received life-insurance policies as their share of an employee-benefit plan that was ending. They argue that surrender charges on both the policies made them worth nothing at the time of their receipt. The Commissioner argues that we must consider only what the insurance company calculated to be the policies’ “stated values” in figuring out what the “amount actually received” by Schwab and Kleinman was. The dispute is a novel one.

Background

Schwab and Kleinman are the sole shareholders of Angels & Cowboys, Inc. 2 They are also employees of the corporation; Schwab works as a graphic designer and Kleinman as a photographer. Schwab has created award-winning logos and posters for clients that include Major League Baseball, the Muhammad Ali Center, Nike, Pebble Beach, Polo Ralph Lauren, Robert Redford, and the San Francisco Opera. One collector described Schwab’s work: “Like a clearing in a dark, unfathomable forest, or an island in a turbulent sea, the graphic art of Michael Schwab is a welcome sight, a safe harbor, amidst the enigmatic and increasingly illegible pool of contemporary art and design.” Merrill C. Berman, Michael Schwab Studio — About Michael, Michael Schwab Studio, http:// www.michaelschwab. com/studio/studio — about, html (last visited Jan. 1, 2011). Kleinman is also highly talented and has done photography for such high-profile clients as Apple Computer, the GAP, Microsoft, and Wolfgang Puck Foods. Studio-Clients, Kathryn Kleinman Studio, http: //www.kathrynkleinman.com/html / studio — clients.html (last visited Jan. 1, 2011).

Accountants follow success, and George Stameroff, a Marin County CPA, was the couple’s accountant until 2001. He prepared Schwab and Kleinman’s tax returns throughout the ‘90s and also gave them financial-planning advice. In 2000, he recommended that the couple buy life-insurance policies through a multiple-employer welfare-benefit trust administered by Benistar. The trust was an employee-benefit plan known as the “Advantage 419 Trust,” because it was designed to conform with section 419A(f)(6). 3 Benistar was aimed at small-business owners and was the nation’s largest administrator of such plans. Stameroff gave Schwab and Kleinman the Benistar marketing brochures that claimed the plan allowed “qualified professionals, entrepreneurs, and closely-held business owners to obtain life insurance for themselves and for key employees on a tax-deductible basis.” These promotional materials emphasized that the plan assets (invested, in Schwab and Kleinman’s case, in an S&P 500 stock-index fund) would grow tax-free and that the death benefits would be income-tax free. According to Stameroff and the Benistar marketing materials, if the plan were terminated, the policies would be distributed to the participants and their value net of surrender charges would be taxable.

Schwab and Kleinman liked what Stameroff had to say about the Advantage 419 Trust and decided to adopt it. But their relationship with Stameroff would soon come to an end. They found out that he was an authorized agent of Benistar and decided to look for another accountant because Schwab felt they “didn’t have a clear rapport with him.” In 2001, Sander Stadtler replaced Stameroff as the couple’s CPA. Stadtler consulted with the couple regarding tax-return preparation and other financial matters. Part of his consultation included an extensive review of the Advantage 419 Trust. He asked Stameroff several questions about the plan to “better understand the various costs and charges in the plan, required contributions, and projected results.” On Stadtler’s recommendation, in 2002 Schwab and Kleinman reduced their death benefits from $5.5 million to $2.4 million. Stadtler also opined that if the couple terminated the plan they would be taxed on the net cash-surrender value of the life-insurance policies.

All seemed well. But roiling in the background was the IRS’s view, which it had held since at least 1995, that most trust arrangements promoted as multiple-employer welfare-benefit funds “do not satisfy the requirements of the section 419A(f)(6) exemption.” Notice 95-34, 1995-1 C.B. 309, 310. In Booth v. Commissioner, 108 T.C. 524 (1997), the Commissioner successfully challenged a plan’s reliance on section 419A(f)(6) by showing that it was really a series of single-employer plans rather than a true multiple-employer plan. In spite of Notice 95-34 and the Commissioner’s litigation success, most taxpayers continued to take the position that their 419 plans were allowable under the Code. The Commissioner raised the stakes in 2000 by designating 419 plans described in Notice 95-34 as “listed transactions.” Notice 2000-15, 2000-1 C.B. 826. 4 Taxpayers are required to disclose listed transactions on their returns, and promoters of such transactions have to register them with the IRS. But many taxpayers took the position that their particular plans weren’t described in Notice 95-34 and so were not “listed transactions.” The IRS then issued proposed regulations on section 419A(f)(6) plans in 2002, sec. 1.419A(f)(6)-l, Proposed Income Tax Regs., 67 Fed. Reg. 45938 (July 11, 2002), that more or less tracked its litigation position.

The proposed regulations caught the attention of BISYS, the plan’s new administrator, who hired outside counsel in 2002 to assess the situation. BISYS eventually concluded that the Advantage 419 Trust would not be able to comply with the proposed regulations. By 2003 it became clear that the Treasury Department would adopt the regulations substantially as proposed; BISYS terminated the plan for all employers, including Angels & Cowboys. The plan then distributed the life-insurance policies to Schwab and EJeinman in October 2003. At the time of distribution, Schwab’s policy had a “policy value” of $48,667 and Kleinman’s had one of $32,576. “Policy value” is an important term in this case, and it’s defined in the plan documents as “premiums less policy loads, plus net investment return, less policy charges, partial surrenders, and any indebtedness.” Schwab and KLeinman had two options upon distribution — continue paying premiums to keep their life-insurance coverage, or surrender the policies for their value less any surrender charges.

But there was a catch. The policies were of a type called variable universal life, a relatively new type of contract for this old industry. A key characteristic of universal life-insurance policies is that they disconnect to some degree a life-insurance feature (i.e., payment of money upon death) from an investment feature (i.e., the use of premiums to acquire assets that fund the insurance payment). The insurer selling a universal-life policy typically segregates payments from its customers in separate investment accounts from which it makes deductions to pay for the insurance component of the policy. At death, the customer’s beneficiary gets what’s left in the separate account.

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Cite This Page — Counsel Stack

Bluebook (online)
136 T.C. No. 6, 136 T.C. 120, 2011 U.S. Tax Ct. LEXIS 7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-p-schwab-and-kathryn-j-kleinman-v-commissioner-tax-2011.