Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
United States Tax Court
Ps, profit-sharing trusts qualified under secs. 401(a) and 501(a), I.R.C. 1954, held limited partnership interests in several partnerships engaging in the wholesale fastener distribution business. Held, Ps realized "unrelated business taxable income" within the meaning of sec. 512, I.R.C. 1954, from their distributive shares of income from such partnerships. Held, further, additions to tax under sec. 6651(a)(1), I.R.C. 1954, imposed.
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Ps, profit-sharing trusts qualified under secs. 401(a) and 501(a), I.R.C. 1954, held limited partnership interests in several partnerships engaging in the wholesale fastener distribution business. Held, Ps realized "unrelated business taxable income" within the meaning of sec. 512, I.R.C. 1954, from their distributive shares of income from such partnerships. Held, further, additions to tax under sec. 6651(a)(1), I.R.C. 1954, imposed. Held, further, respondent is not estopped from asserting the deficiencies and additions to tax at issue.
1Opinion of the Court
OPINION
Nims, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes:
Docket No. TYE Deficiency Additions to tax sec. 6651(a)(1)2
1438-80 Service Bolt & Nut Co. Profit Sharing Trust 9/30/75 $38,946.72 $9,736.68
1439-80 Service Bolt & Nut of Akron, Inc. Profit Sharing Trust 12/31/74 12/31/75 9,146.07 3,163.72 2,286.52 790.93
1440-80 Service Bolt & Nut of Pennsylvania, Inc. Profit Sharing Trust 12/31/74 4,125.25 1,031.31
The issues for decision are: (1) Whether petitioners, as profit-sharing trusts qualified under sections 401(a) and…
2Cases cited13 opinions
- Commissioner v. HansenSupreme Court of the United States · 1959
- George Van Camp & Sons Co. v. American Can Co.Supreme Court of the United States · 1929
- West Side Tennis Club v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
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- Heman v. CommissionerUnited States Tax Court · 1959
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