Service Bolt & Nut Co. v. Commissioner

JOHN W. PECK, Senior Circuit Judge.

The principal issue raised by this appeal is one of first impression, namely, whether income received by profit sharing trusts qualified under § 401 of the Internal Revenue Code, 26 U.S.C. § 401,1 from their limited partnership interests constituted unrelated business taxable income under § 512. Other issues raised by this appeal include whether the taxpayers were liable for additions to tax under § 6651(a)(1), whether the Commissioner of Internal Revenue was es-topped from assessing the deficiencies and additions to tax at issue after abating an initial,…