Legal Opinion
Fuqua National, Inc. v. United States
District Court, S.D. Georgia
Decided December 2, 1971No. Civ. A. Nos. 1390, 1391PublishedCited by 2 opinions
1Opinion of the Court
ORDER
LAWRENCE, Chief Judge.
In these actions plaintiffs sue to recover income taxes paid under protest following disallowance of deductions in connection with an Employees’ Profit Share and Retirement Trust. The Commissioner ruled that the Trust had engaged in a prohibited transaction during the fiscal year 1958-1959 and that it thereby lost its status as an exempt organization.1
The transaction concerned was the alleged loan of trust corpus to the employer-creator, Georgia-Carolina Broadcasting Company (now Fuqua National, Inc.) without adequate security. See 26 U.S. C.A. §§ 501, 503(a), (b),…
2Cases cited5 opinions
- James v. United StatesDistrict Court, D. Nevada · 1959
- Van Products, Inc. v. CommissionerUnited States Tax Court · 1963
- L. O. Crosby, Jr., and Dorothy H. Crosby v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Crosby v. United StatesDistrict Court, S.D. Mississippi · 1968
- Azad v. United StatesDistrict Court, D. Minnesota · 1966
3Cited by2 opinions
- United States v. John A. CerritoCourt of Appeals for the First Circuit · 1979
- United States Underwriters Inc. v. Simcoe & Erie General InsuranceDistrict Court, S.D. New York · 1982