Lansons, Inc. v. Commissioner
United States Tax Court
Petitioner Lansons, Inc., established a profit-sharing trust for the benefit of its employees in 1968. At the suggestion of respondent in response to a ruling request, the eligibility requirements were amended to require only that the employee be between the ages of 25 and 66 and have 1 full year of service.
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Petitioner Lansons, Inc., established a profit-sharing trust for the benefit of its employees in 1968. At the suggestion of respondent in response to a ruling request, the eligibility requirements were amended to require only that the employee be between the ages of 25 and 66 and have 1 full year of service. Respondent thereupon issued a ruling letter that the trust qualified under sec. 401(a). After an audit on Dec. 1, 1972, respondent wrote petitioners a letter revoking his favorable ruling retroactively, and disallowed deductions for contributions made by Lansons to the trust in 1969,…
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in Federal income tax as follows:
Docket No. Petitioner FYE Aug. Sl-Deficiency
9336-74 Lansons, Inc. .1969 $7,509.58
1970 8,546.65
1971 10,035.19
9347-74 Lansons, Inc., Profit-Sharing Trust: Louis Levine and A. J. Kaiser, trustees. 1971 165.87
One issue in docket No. 9336-74 was conceded by petitioner at trial, and the only issue in docket No. 9347-74 was conceded by respondent on brief. The single issue left to be decided is whether under section 404(a)(3), I.R.C. 1954,1 Lansons, Inc., is entitled to deductions for contributions to a…
2Cases cited12 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Ed & Jim Fleitz, Inc. v. CommissionerUnited States Tax Court · 1968
- Loevsky v. CommissionerUnited States Tax Court · 1971
- Bernard McMenamy Contractor, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1971
- Bernard McMenamy, Contractor, Inc. v. CommissionerUnited States Tax Court · 1970
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3Cited by33 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Elkins v. CommissionerUnited States Tax Court · 1983
- Buzzetta Constr. Corp. v. CommissionerUnited States Tax Court · 1989
- Lansons, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1980
- Oakton Distributors, Inc. v. CommissionerUnited States Tax Court · 1979
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