Legal Opinion

Burton v. Commissioner

United States Tax Court

Decided December 17, 1992No. Docket Nos. 12970-90, 12971-90Published

P was a plastic surgeon and the sole shareholder-employee of P.A., a professional association. P was covered by P.A.'s qualified profit-sharing and pension plans. P liquidated P.A. during October 1984. Immediately after the liquidation, P resumed his surgical practice in the form of a sole proprietorship. P.A. and the sole proprietorship were located at the same address. In December 1985 and January 1986 P received distributions from P.A.'s qualified plans.

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P was a plastic surgeon and the sole shareholder-employee of P.A., a professional association. P was covered by P.A.'s qualified profit-sharing and pension plans. P liquidated P.A. during October 1984. Immediately after the liquidation, P resumed his surgical practice in the form of a sole proprietorship. P.A. and the sole proprietorship were located at the same address. In December 1985 and January 1986 P received distributions from P.A.'s qualified plans. Held, P's change of status from that of a sole shareholder-employee of P.A. to that of a sole proprietor does not constitute a…

1Opinion of the Court

Francis C. Burton, Jr., and Helen H. Burton, Petitioners v. Commissioner of Internal Revenue, Respondent

Burton v. Commissioner

Docket Nos. 12970-90, 12971-90

United States Tax Court

99 T.C. 622; 1992 U.S. Tax Ct. LEXIS 87; 99 T.C. No. 32; 16 Employee Benefits Cas. (BNA) 1057;

December 17, 1992, Filed

Decisions will be entered for respondent.

P was a plastic surgeon and the sole shareholder-employee of P.A., a professional association. P was covered by P.A.'s qualified profit-sharing and pension plans. P liquidated P.A. during October 1984. Immediately after the liquidation, P resumed his surgical…

2Cases cited17 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
  3. United States v. Ophelia Johnson and Ophelia R. Johnson, as Under the Last Will and Testament of Clifford L. Johnson, DeceasedCourt of Appeals for the Fifth Circuit · 1964
  4. Crow v. CommissionerUnited States Tax Court · 1985
  5. Gittens v. CommissionerUnited States Tax Court · 1968

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