Legal Opinion
Leavens v. Commissioner
Court of Appeals for the Third Circuit
Decided September 22, 1972No. Nos. 71-1675, 71-1677 and 71-1678PublishedCited by 3 opinions
1Opinion of the Court
OPINION OF THE COURT
MAX ROSENN, Circuit Judge.
The sole question in this case is whether money set aside for the appellants under an employees’ qualified profit-sharing plan was made available to them, and therefore taxable, during the period from 1956-59.
Appellants had signed multilateral agreements prohibiting each other from withdrawing any funds for a period of several years. They contend that although the private agreements were not executed by all of the participants in the *811plan, the agreements significantly restrained the signatories’ right to the funds so as not to make them available,…
2Cases cited9 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- United States v. PfisterCourt of Appeals for the Eighth Circuit · 1953
- Weil v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Johnson v. CommissionerUnited States Tax Court · 1955
- Rhombar Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Blyler v. CommissionerUnited States Tax Court · 1977
- William B. Leavens, Jr. And Emeline P. Leavens, in No. 71-1675. v. Commissioner of Internal Revenue. Robert Glass and Mae C. Glass, in No. 71-1677 v. Commissioner of Internal Revenue. John Last and Marie Last, in No. 71-1678 v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1972
- Blyler v. CommissionerUnited States Tax Court · 1977