Legal Opinion
Citrus Valley Estates, Inc. v. Commissioner
Court of Appeals for the Ninth Circuit
Decided March 8, 1995No. Nos. 93-70486 to 93-70488, 93-70491 to 93-70496, 93-70498 to 93-70500PublishedCited by 7 opinions
1Opinion of the Court
CYNTHIA HOLCOMB HALL, Circuit Judge:
Appellees (collectively, “Taxpayers”) are all small businesses or professional corporations. Each had in place a qualified individual defined benefit (“IDB”) pension plan for employees. In 1989, the Internal Revenue Service audited Taxpayers’ IDB plans as part of the Service’s so-called Small Plan Audit Program. The Small Plan Audit Program represented the. Service’s attempt to crack down on what it believed were abusive tax practices.
As part of the Small Plan Audit Program, the Service audited thousands of IDB plans. Many plan sponsors were assessed…
2Cases cited8 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Vinson & Elkins, J. Evans Attwell, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
- Wachtell, Lipton, Rosen & Katz, David M. Einhorn, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Citrus Valley Estates v. CommissionerUnited States Tax Court · 1992
- Jerome Mirza & Associates, Ltd., an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1989
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Chicago Truck Drivers, Helpers & Warehouse Workers Union (Independent) Pension Fund v. CPC Logistics, Inc.Court of Appeals for the Seventh Circuit · 2012
- Citrus Valley Estates, Inc. v. Commissioner Internal Revenue Service, Citrus Valley Estates, Inc. v. Commissioner Internal Revenue Service, Robert J. Davis Janice A. Davis v. Commissioner Internal Revenue Service, Old Frontier Investment, Inc., of Arizona v. Commissioner Internal Revenue Service, Robert Stephan, Jr. v. Commissioner Internal Revenue Service, Boren Steel Consultants, Inc. v. Commissioner Internal Revenue Service, Boren Steel Consultants, Inc. v. Commissioner Internal Revenue Service, Lear Eye Clinic, Ltd., an Arizona Professional Corporation v. Commissioner Internal Revenue Service, Lear Eye Clinic, Ltd., an Arizona Professional Corporation v. Commissioner Internal Revenue Service, Arizona Orthopedic Institute of Traumatic and Reconstructive Surgery, P.C. v. Commissioner Internal Revenue Service, Jonathan R. Fox Renee K. Fox v. Commissioner Internal Revenue Service, Brody Enterprises, Inc. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Lear Eye Clinic v. CommissionerUnited States Tax Court · 1996
- GCIU-EMPLOYER RETIREMENT FUND V. MNG ENTERPRISES, INC.Court of Appeals for the Ninth Circuit · 2022
- Lear Eye Clinic v. CommissionerUnited States Tax Court · 1996
2 more not listed; retrieve them via the Exa API.