Kern County Electrical Pension Fund v. Commissioner
United States Tax Court
T is a tax-exempt organization pursuant to secs. 401(a) and 501(a). It owned certificates of deposit (old certificates) in Valley Federal Savings & Loan Association, the account balances of which could be withdrawn prior to maturity minus a substantial reduction of the interest that had been paid or was then payable.
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T is a tax-exempt organization pursuant to secs. 401(a) and 501(a). It owned certificates of deposit (old certificates) in Valley Federal Savings & Loan Association, the account balances of which could be withdrawn prior to maturity minus a substantial reduction of the interest that had been paid or was then payable. At a time when interest rates were rising sharply, at Valley Federal's suggestion, T entered into an arrangement to obtain "savings account loans" from Valley Federal with its old certificates as collateral and to invest the proceeds of the loans in new certificates reflecting…
1Opinion of the Court
OPINION
RAUM, Judge:
The Commissioner determined a deficiency in the income tax of Kern County Electrical Pension Fund (petitioner or the pension fund) in the amount of $12,371 for its 1980 taxable year. Petitioner had its principal office in Bakersfield, California, on the date it filed the petition in this case. The case was submitted pursuant to a stipulation of facts and exhibits under our Rule 122.1 The issue for decision is whether petitioner is liable for the tax on unrelated business taxable income imposed by section 511, often referred to informally as UBIT.
Petitioner is an employee…
2Cases cited13 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Stringer v. CommissionerUnited States Tax Court · 1985
- Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
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3Cited by11 opinions
- Bartels Trust for Benefit of Cornell University Ex Rel. Bartels v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Chronicle Pub. Co. v. CommissionerUnited States Tax Court · 1991
- CRSO v. Comm'rUnited States Tax Court · 2007
- Henry E. & Nancy Horton Bartels Trust For The Benefit Of The University Of New Haven v. United StatesCourt of Appeals for the Second Circuit · 2000
- Henry E. & Nancy Horton Bartels Trust for the Benefit of the University of New Haven v. United StatesCourt of Appeals for the Second Circuit · 2000
6 more not listed; retrieve them via the Exa API.