Legal Opinion

Gillis v. Commissioner

United States Tax Court

Decided October 2, 1974No. Docket Nos. 7492-72, 273-73PublishedCited by 14 opinions

B-G corporation made entries on its books at the end of each year accruing liabilities for payments under a profit-sharing plan meeting the requirements of secs. 401 and 501, I.R.C. 1954, and informed the employees of their respective shares of the accruals. B-G's treasurer was also a trustee under the plan.

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B-G corporation made entries on its books at the end of each year accruing liabilities for payments under a profit-sharing plan meeting the requirements of secs. 401 and 501, I.R.C. 1954, and informed the employees of their respective shares of the accruals. B-G's treasurer was also a trustee under the plan. She purchased certain stocks for the trust during B-G's taxable years ended Mar. 31, 1967, and Mar. 31, 1968, but did not pay or otherwise transfer to the trust $ 24,236.67 and $ 11,807.48 taken as deductions in those years, respectively, until Aug. 5, 1968. Petitioners have agreed that…

1Opinion of the Court

Featherston, Judge:

Respondent has determined that each of the petitioners in these consolidated cases is liable as a transferee for income tax deficiencies due from 2560 Corp. (formerly B-G Equipment Co., Inc.), transferor, for the taxable years ended March 31, 1967, and March 31, 1968. The deficiencies so determined are in the amounts of $11,633.60 and $6,762.15 for those years, respectively. Petitioners acknowledge that each of them is a transferee of the assets of 2560 Corp. within the meaning of section 6901,1 but they allege that respondent erred in his determination of deficiencies in…

2Cases cited13 opinions

  1. Fountain v. CommissionerUnited States Tax Court · 1973
  2. Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  3. F. & D. Rentals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1966
  4. F. & D. Rentals, Inc. v. CommissionerUnited States Tax Court · 1965
  5. Sachs v. Commissioner of Internal Revenue. Slaymaker Lock Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953

8 more not listed; retrieve them via the Exa API.

3Cited by14 opinions

  1. Tionesta Sand & Gravel, Inc. v. CommissionerUnited States Tax Court · 1980
  2. D.J. Lee, M.D., Inc. v. CommissionerUnited States Tax Court · 1989
  3. Schmidt Baking Co. v. CommissionerUnited States Tax Court · 1996
  4. Hamlin Dev. Co. v. CommissionerUnited States Tax Court · 1993
  5. Rollar Homes, Inc. v. CommissionerUnited States Tax Court · 1987

9 more not listed; retrieve them via the Exa API.

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