Mortenson Roofing Co. v. Commissioner
United States Tax Court
R determined that P's profit-sharing plan does not satisfy the requirements of section 401(a), I.R.C., for plan years beginning on and after October 31, 1984, and therefore the plan is not exempt from taxation under section 501(a), I.R.C. P contends that R is estopped from determining that P's plan does not comply with section 401(a), I.R.C.Held, R's determination is sustained.
1Opinion of the Court
MORTENSON ROOFING COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mortenson Roofing Co. v. Commissioner
Docket No. 24819-89R.
United States Tax Court
T.C. Memo 1992-112; 1992 Tax Ct. Memo LEXIS 133; 63 T.C.M. (CCH) 2186; T.C.M. (RIA) 92112;
February 24, 1992, Filed
Decision will be entered for respondent
R determined that P's profit-sharing plan does not satisfy the requirements of section 401(a), I.R.C., for plan years beginning on and after October 31, 1984, and therefore the plan is not exempt from taxation under section 501(a), I.R.C. P contends that R is estopped from…
2Cases cited6 opinions
- Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- Boulez v. CommissionerUnited States Tax Court · 1981
- Kronish v. CommissionerUnited States Tax Court · 1988
- Dimitrious J. Lignos and Evelyn Lignos v. United StatesCourt of Appeals for the Second Circuit · 1971
- Century Data Sys. ex rel. California Computer Prods. v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Mills, Mitchell & Turner v. CommissionerUnited States Tax Court · 1993