Bianchi v. Commissioner
United States Tax Court
Petitioner-husband organized a corporation for his dental practice, which elected subch. S status. The corporation elected a first taxable year of 7 days during which it adopted a pension plan covering petitioner-husband and his dental assistant.
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Petitioner-husband organized a corporation for his dental practice, which elected subch. S status. The corporation elected a first taxable year of 7 days during which it adopted a pension plan covering petitioner-husband and his dental assistant. The corporation made its initial contribution to the plan covering the ensuing 12 months on the last day of its first (7-day) taxable year from funds lent to the corporation by petitioner secured by a demand, non-interest-bearing note. The deduction produced a net operating loss for the corporation which petitioners deducted on their return. Held,…
1Opinion of the Court
Angelo J. and Ida A. Bianchi, Petitioners v. Commissioner of Internal Revenue, Respondent
Bianchi v. Commissioner
Docket No. 8152-74
United States Tax Court
66 T.C. 324; 1976 U.S. Tax Ct. LEXIS 104;
May 20, 1976, Filed
Decision will be entered for the respondent.
Petitioner-husband organized a corporation for his dental practice, which elected subch. S status. The corporation elected a first taxable year of 7 days during which it adopted a pension plan covering petitioner-husband and his dental assistant. The corporation made its initial contribution to the plan covering the ensuing 12 months on the…
2Cases cited20 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Charles Oran Mensik and Mary Mensik v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
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