White v. Comr., T.C. Memo. 2012-104

(medical service corporation made contributions to I.R.C. Sec. 419 multi-employer benefit plan; contributions not deductible as ordinary and necessary business expenses under I.R.C. Sec. 162 because facts indicated that contributions made on behalf of owner of corporation and owner's wife to fund personal investment in whole life insurance policies that largely accumulated cash value just for them; petitioner had full control over policies).