Wisconsin Nipple & Fabricating Corp. v. Commissioner
United States Tax Court
Held, during the years in issue, the eligibility requirements of the petitioner's profit-sharing plan operated in a discriminatory manner in violation of sec. 401(a)(3)(B), I.R.C. 1954; held, further, the Commissioner's retroactive revocation of the qualified status of the petitioner's plan did not constitute an abuse of his discretion.
1Opinion of the Court
Simpson, Judge:
The Commissioner has determined the following deficiencies in the petitioner’s Federal corporate income taxes:
Year ending
Apr. 30— Deficiency
1972. $6,051.94
1973. 6,132.46
We must decide whether the petitioner’s profit-sharing plan qualified during the years in issue, and if not, whether the Commissioner’s retroactive revocation of its qualified status constituted an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioner, Wisconsin Nipple & Fabricating Corp., is a Wisconsin corporation, which had its principal office…
2Cases cited20 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- The Lesavoy Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
15 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Lansons, Inc. v. CommissionerUnited States Tax Court · 1978
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
- Oakton Distributors, Inc. v. CommissionerUnited States Tax Court · 1979
- Virginia Education Fund v. CommissionerUnited States Tax Court · 1985
- Pulver Roofing Co. v. CommissionerUnited States Tax Court · 1978
21 more not listed; retrieve them via the Exa API.