Legal Opinion

Gary L. Eyler v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided July 2, 1996No. 95-2482PublishedCited by 56 opinions

1Opinion of the Court

TERENCE T. EVANS, Circuit Judge.

Gary Eyler, the former CEO and majority shareholder of Continental Training Services, Inc. (CTS), disputes excise taxes assessed against him by the Commissioner of Internal Revenue in 1992. The Commissioner determined that Eyler, as the majority owner of CTS stock, engaged in a prohibited transaction with CTS’s employee stock ownership plan (ESOP) when he sold $10 million worth of CTS stock to the ESOP in December 1986.

Eyler appealed the Commissioner’s determination to the Tax Court. After a 1995 trial, the Tax Court concluded that Eyler was not exempt from…

2Cases cited15 opinions

  1. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. United States v. CartwrightSupreme Court of the United States · 1973
  4. Katsaros v. CodyCourt of Appeals for the Second Circuit · 1984
  5. Donovan v. CunninghamCourt of Appeals for the Fifth Circuit · 1983

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3Cited by56 opinions

  1. Equal Employment Opportunity Commission v. Ilona of Hungary, IncorporatedCourt of Appeals for the Seventh Circuit · 1997
  2. In Re Enron Corp. Securities, Derivative & ERISADistrict Court, S.D. Texas · 2003
  3. Bonnie Fish v. Greatbanc Trust CompanyCourt of Appeals for the Seventh Circuit · 2014
  4. In Re Citigroup ERISA LitigationCourt of Appeals for the Second Circuit · 2011
  5. Debra K. Keach and Patricia A. Sage v. U.S. Trust Company, Formerly Known as U.S. Trust Company of California N.A.Court of Appeals for the Seventh Circuit · 2005

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