Legal Opinion

Kern County Electrical Pension Fund v. Commissioner

United States Tax Court

Decided June 20, 1991No. Docket No. 4843-89Published

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of deposit (old certificates) in Valley Federal Savings & Loan Association, the account balances of which could be withdrawn prior to maturity minus a substantial reduction of the interest that had been paid or was then payable.

Read the full summary

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of deposit (old certificates) in Valley Federal Savings & Loan Association, the account balances of which could be withdrawn prior to maturity minus a substantial reduction of the interest that had been paid or was then payable.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

Kern County Electrical Pension Fund, Petitioner v. Commissioner of Internal Revenue, Respondent

Kern County Electrical Pension Fund v. Commissioner

Docket No. 4843-89

United States Tax Court

96 T.C. 845; 1991 U.S. Tax Ct. LEXIS 53; 96 T.C. No. 41; 14 Employee Benefits Cas. (BNA) 1045;

June 20, 1991, Filed

Decision will be entered for the respondent.

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of deposit (old certificates) in Valley Federal Savings & Loan Association, the account balances of which could be withdrawn prior to maturity minus a substantial…

2Cases cited14 opinions

  1. Commissioner v. BrownSupreme Court of the United States · 1965
  2. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  3. Stringer v. CommissionerUnited States Tax Court · 1985
  4. Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
  5. University Hill Foundation v. CommissionerUnited States Tax Court · 1969

9 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API