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
Lansons, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Lansons, Inc., Profit-Sharing Trust: Louis Levine, A. J. Kaiser, Trustees, Petitioner v. Commissioner of Internal Revenue, Respondent
Lansons, Inc. v. Commissioner
Docket Nos. 9336-74, 9347-74
United States Tax Court
69 T.C. 773; 1978 U.S. Tax Ct. LEXIS 167;
February 27, 1978, Filed
Decision will be entered for the petitioner in docket No. 9347-74.
Decision will be entered under Rule 155 in docket No. 9336-74.
Petitioner Lansons, Inc., established a profit-sharing trust for the benefit of its employees in 1968. At the…
Also in this document: Dissent.
2Cases cited18 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
- Ed & Jim Fleitz, Inc. v. CommissionerUnited States Tax Court · 1968
- Loevsky v. CommissionerUnited States Tax Court · 1971
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