Adams v. Commissioner
United States Tax Court
Subsequent to the filing of the opinion in the case of Adams v. Commissioner, 70 T.C. 373 (1978), and upon its own motion, this Court directs that the parties therein submit briefs addressing the issue as to whether this Court has the statutory authority to determine a deficiency in tax under sec. 4941(b)(1), I.R.C. 1954.
1Opinion of the Court
SUPPLEMENTAL OPINION
Fay, Judge:
On May 30, 19.78, our Findings of Fact and Opinion1 were filed in this case (70 T.C. 373 (1978)), which, in part, sustained respondent’s determination that petitioner, was subject to a 5-percent excise tax individually and as transferee of Automatic Accounting Co., under section 4941(a)(1)2 for certain acts of self-dealing which occurred between a private foundation and petitioner and Automatic. Pursuant to the opinion, decisions in docket Nos. 6977-74, 6978-74,-and 6980-74 will be entered under Rule 155.
Respondent further asserted a deficiency in tax under…
2Cases cited3 opinions
- Laing v. United StatesSupreme Court of the United States · 1976
- Adams v. CommissionerUnited States Tax Court · 1978
- Bendheim v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
3Cited by17 opinions
- Adams v. CommissionerUnited States Tax Court · 1979
- Menard, Inc. v. Comm'rUnited States Tax Court · 2008
- Freedman v. CommissionerUnited States Tax Court · 1979
- Zabolotny v. CommissionerUnited States Tax Court · 1991
- Adams v. CommissionerUnited States Tax Court · 1978
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