VEBAs--ordinary and necessary expenses--deductions and constructive dividends. Neonatology Associates, P.A. v. Commissioner of Internal Revenue

Contributions made by professional medical corporations into voluntary employee benefit program plans (VEBAs), which were well in excess of the cost of the term life insurance provided to the participants, were not ordinary and necessary business expenses, and the distributions of surplus cash to owner physicians upon conversion to individual policies constituted constructive dividends taxable to the individual taxpayers.