Legal Opinion

Hill, Farrer & Burrill v. Commissioner

United States Tax Court

Decided December 14, 1976No. Docket No. 3942-76RPublished

Petitioner, a 19-member partnership engaged in the practice of law, adopted an employees' profit-sharing plan which meets all the requirements for qualification except certain ones applicable to plans which provide contributions or benefits for employees some or all of whom are "owner-[employees]" as defined in sec. 401(c)(3)(B), I.R.C. 1954. Petitioner's capital gains and one-third of its net profits are divided among its partners in proportion to their substantially equal…

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Petitioner, a 19-member partnership engaged in the practice of law, adopted an employees' profit-sharing plan which meets all the requirements for qualification except certain ones applicable to plans which provide contributions or benefits for employees some or all of whom are "owner-[employees]" as defined in sec. 401(c)(3)(B), I.R.C. 1954. Petitioner's capital gains and one-third of its net profits are divided among its partners in proportion to their substantially equal capital contributions, and the other two-thirds of its profits are divided "on the basis that the total profit to the…

1Opinion of the Court

Hill, Farrer & Burrill, A General Partnership, Petitioner v. Commissioner of Internal Revenue, Respondent

Hill, Farrer & Burrill v. Commissioner

Docket No. 3942-76R

United States Tax Court

67 T.C. 411; 1976 U.S. Tax Ct. LEXIS 11; 1 Employee Benefits Cas. (BNA) 2232;

December 14, 1976, Filed

Petitioner, a 19-member partnership engaged in the practice of law, adopted an employees' profit-sharing plan which meets all the requirements for qualification except certain ones applicable to plans which provide contributions or benefits for employees some or all of whom are "owner-[employees]" as defined in…

Also in this document: Concurrence; Dissent.

2Cases cited12 opinions

  1. United States v. Arthur R. Kintner and Alyce KintnerCourt of Appeals for the Ninth Circuit · 1954
  2. Packard v. CommissionerUnited States Tax Court · 1975
  3. United States v. R. T. And Gertrude WoolseyCourt of Appeals for the Fifth Circuit · 1964
  4. Lester Wm. Roth and Gertrude F. Roth v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  5. Joyce v. CommissionerUnited States Tax Court · 1964

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