Legal Opinion

Fazi v. Commissioner

United States Tax Court

Decided May 19, 1994No. Docket No. 13139-91Published

P, a dentist, incorporated C and established three employee plans. P was the sole shareholder, director, and officer of C. Prior to 1984, the plans were modified from time to time to comply with internal revenue law changes. With the 1982 and 1984 enactment of numerous changes to the pension provisions of the Internal Revenue Code, C's plan became "top-heavy", and changes were made to cause it to be operationally in compliance with revenue laws.

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P, a dentist, incorporated C and established three employee plans. P was the sole shareholder, director, and officer of C. Prior to 1984, the plans were modified from time to time to comply with internal revenue law changes. With the 1982 and 1984 enactment of numerous changes to the pension provisions of the Internal Revenue Code, C's plan became "top-heavy", and changes were made to cause it to be operationally in compliance with revenue laws. G, an insurance company, devised a modified prototype plan which was generally approved by the Internal Revenue Service. Although C's plan was…

1Opinion of the Court

John U. Fazi and Sylvia Fazi, Petitioners v. Commissioner of Internal Revenue, Respondent

Fazi v. Commissioner

Docket No. 13139-91

United States Tax Court

102 T.C. 695; 1994 U.S. Tax Ct. LEXIS 34; 102 T.C. No. 31; 18 Employee Benefits Cas. (BNA) 1643;

May 19, 1994, Filed

Decision will be entered under Rule 155.

P, a dentist, incorporated C and established three employee plans. P was the sole shareholder, director, and officer of C. Prior to 1984, the plans were modified from time to time to comply with internal revenue law changes. With the 1982 and 1984 enactment of numerous changes to the pension…

2Cases cited19 opinions

  1. Brewer v. First National BankSupreme Court of Virginia · 1961
  2. Harold D. Greenwald and Nana Greenwald, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1966
  3. Buzzetta Constr. Corp. v. CommissionerUnited States Tax Court · 1989
  4. Greenwald v. CommissionerUnited States Tax Court · 1965
  5. Ludden v. CommissionerUnited States Tax Court · 1977

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