Epstein v. Commissioner
United States Tax Court
At the time a pension plan was being terminated, the base for calculating benefits to be distributed was changed to include bonuses in addition to salaries paid to covered employees. Held, such change caused such plan not to be qualified under sec. 401(a)(4), I.R.C. 1954. Held, further, the entire amount of benefits received by petitioner is taxable as ordinary income.
1Opinion of the Court
Perry Epstein and Mildred Epstein, Petitioners v. Commissioner of Internal Revenue, Respondent
Epstein v. Commissioner
Docket No. 6393-75
United States Tax Court
70 T.C. 439; 1978 U.S. Tax Ct. LEXIS 103;
June 13, 1978, Filed
Decision will be entered for the respondent.
At the time a pension plan was being terminated, the base for calculating benefits to be distributed was changed to include bonuses in addition to salaries paid to covered employees. Held, such change caused such plan not to be qualified under sec. 401(a)(4), I.R.C. 1954. Held, further, the entire amount of benefits received by…
2Cases cited7 opinions
- City of New York v. SaperSupreme Court of the United States · 1949
- Harold D. Greenwald and Nana Greenwald, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1966
- 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
- Greenwald v. CommissionerUnited States Tax Court · 1965
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