Adams v. Commissioner
United States Tax Court
On May 30, 1978, our findings of fact and an opinion were filed in this case (70 T.C. 373 (1978)), which, in part, sustained respondent's determination that petitioner was subject to a 5-percent excise tax, individually and as transferee of Automatic Accounting Co., under sec. 4941(a)(1), I.R.C. 1954, for certain acts of self-dealing which occurred between a private foundation and petitioner and Automatic Accounting Co. With respect to the same acts of self-dealing,…
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On May 30, 1978, our findings of fact and an opinion were filed in this case (70 T.C. 373 (1978)), which, in part, sustained respondent's determination that petitioner was subject to a 5-percent excise tax, individually and as transferee of Automatic Accounting Co., under sec. 4941(a)(1), I.R.C. 1954, for certain acts of self-dealing which occurred between a private foundation and petitioner and Automatic Accounting Co. With respect to the same acts of self-dealing, respondent also asserted deficiencies in tax under sec. 4941(b)(1). The above-noted opinion did not address petitioner's…
1Opinion of the Court
SUPPLEMENTAL OPINION
Fay, Judge:
On May 17,1974, respondent mailed to petitioner, Paul W. Adams, six statutory notices of deficiency in which he determined various chapter 42 excise tax deficiencies under Code section 49411 against petitioner, individually and as transferee of Automatic Accounting Co. (Automatic), a corporation wholly owned by petitioner. The asserted deficiencies arose out of several alleged “acts of self-dealing” between a private foundation and petitioner and Automatic.
Subsequent to the filing of the petitions in these cases, a trial was held in Bridgeport, Conn., on October…
2Cases cited3 opinions
- Adams v. CommissionerUnited States Tax Court · 1978
- Adams v. CommissionerUnited States Tax Court · 1978
- Heasley v. CommissionerUnited States Tax Court · 1966
3Cited by38 opinions
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Friends of Soc. of Servants of God v. CommissionerUnited States Tax Court · 1980
- H. Fort Flowers Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Larchmont Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Howell v. CommissionerUnited States Tax Court · 1981
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