Goyak v. Comr., T.C. Memo. 2012-13

(contribution of company controlled by petitioner to I.R.C. §419A(f)(6) plan in attempt to provide covered employees with severance and other benefits funded via whole life insurance not deductible business expense, but was constructive dividend to company’s only covered employee (petitioner’s spouse) for petitioner’s personal benefit; attempt to provide tax-free income to petitioner and spouse; accuracy-related penalty imposed).