Lee Eng'g Supply Co. v. Commissioner
United States Tax Court
In 1985, P, a corporation, decided to terminate its defined benefit pension plan (pension plan). P did not make a contribution required under the minimum funding provisions of sec. 412, I.R.C., by Oct. 15, 1985. Held: P's pension plan had an accumulated funding deficiency in FYE 1985 subject to the 5-percent excise tax under sec. 4971, I.R.C.D.J. Lee, M.D., Inc. v. Commissioner, 92 T.C. 291, 300 (1989), affd. 931 F.2d 418 (6th Cir. 1991), followed.
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In 1985, P, a corporation, decided to terminate its defined benefit pension plan (pension plan). P did not make a contribution required under the minimum funding provisions of sec. 412, I.R.C., by Oct. 15, 1985. Held: P's pension plan had an accumulated funding deficiency in FYE 1985 subject to the 5-percent excise tax under sec. 4971, I.R.C.D.J. Lee, M.D., Inc. v. Commissioner, 92 T.C. 291, 300 (1989), affd. 931 F.2d 418 (6th Cir. 1991), followed. At the time P terminated its pension plan in FYE 1987, the plan's assets exceeded the plan's liabilities by $ 16,241, which amount P transferred…
1Opinion of the Court
Lee Engineering Supply Co., Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Lee Eng'g Supply Co. v. Commissioner
Docket No. 19267-90
United States Tax Court
101 T.C. 189; 1993 U.S. Tax Ct. LEXIS 53; 101 T.C. No. 12; 17 Employee Benefits Cas. (BNA) 1536;
August 30, 1993, Filed
Decision will be entered for respondent with respect to the deficiencies in excise taxes for fiscal years ended 1985 and 1987 and with respect to the additions to tax for the fiscal year ended 1985; decision will be entered for petitioner with respect to the additions to tax for fiscal year ended 1987.
In 1985,…
2Cases cited8 opinions
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1980
- D.J. Lee, M.D., Inc. v. CommissionerUnited States Tax Court · 1989
- International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, Uaw v. Keystone Consolidated Industries, Inc.Court of Appeals for the Seventh Circuit · 1986
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