New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
United States Tax Court
In 1973, the Brewery Workers Fund and the Teamsters Fund agreed to merge. Subsequent to the agreement, but prior to the date of the merger, Reingold Breweries, one of the largest employer contributors to the Brewery Workers Fund, ceased operations. The Teamsters Fund refused to proceed with the merger. The New York State Supreme Court ordered the Teamsters to specifically perform the merger agreement.
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In 1973, the Brewery Workers Fund and the Teamsters Fund agreed to merge. Subsequent to the agreement, but prior to the date of the merger, Reingold Breweries, one of the largest employer contributors to the Brewery Workers Fund, ceased operations. The Teamsters Fund refused to proceed with the merger. The New York State Supreme Court ordered the Teamsters to specifically perform the merger agreement. On Sept. 28, 1976, the Internal Revenue Service issued a determination that the merger amendment would not affect the existing qualification of the Teamsters Fund. Subsequently, the New York…
1Opinion of the Court
OPINION
NlMS, Judge:
These cases were heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code.2 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
Petitioners in these consolidated cases brought actions for declaratory judgment under section 7476.3 Petitioners in these cases are as follows:
Docket No. Identity Relationship
12445-85R
New York State Teamsters Conference Pension and Retirement Fund by Rocco DePerno, Paul F. Bush, Jack Canzoneri, T.…
2Cases cited13 opinions
- Soriano v. CommissionerUnited States Tax Court · 1988
- Thompson v. CommissionerUnited States Tax Court · 1978
- New York State Teamsters Conference Pension & Retirement Fund v. HohDistrict Court, N.D. New York · 1982
- New York State Teamsters Conference Pension and Retirement Fund v. Pension Benefit Guaranty CorporationCourt of Appeals for the D.C. Circuit · 1979
- Cicatello v. Brewery Workers Pension FundDistrict Court, W.D. New York · 1977
8 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Loftus v. CommissionerUnited States Tax Court · 1988
- Thomas Rocco v. New York State Teamsters Conference Pension And Retirement FundCourt of Appeals for the Second Circuit · 2002
- Rocco v. New York State Teamsters Conference Pension & Retirement FundCourt of Appeals for the Second Circuit · 2002
- Dillon v. CommissionerUnited States Tax Court · 1993
- Loftus v. CommissionerUnited States Tax Court · 1988
1 more not listed; retrieve them via the Exa API.