Barth Foundation v. Commissioner
United States Tax Court
On May 14, 1980, respondent mailed two notices of deficiency to petitioner in which he determined first tier and second tier excise taxes under sec. 4942(a) and 4942(b), I.R.C. 1954, as amended, for failure to distribute in 1974 and 1975 income earned in 1973 and 1974. On Oct. 14, 1980, petitions were filed disputing those determinations. On Dec. 24, 1980, Pub.
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On May 14, 1980, respondent mailed two notices of deficiency to petitioner in which he determined first tier and second tier excise taxes under sec. 4942(a) and 4942(b), I.R.C. 1954, as amended, for failure to distribute in 1974 and 1975 income earned in 1973 and 1974. On Oct. 14, 1980, petitions were filed disputing those determinations. On Dec. 24, 1980, Pub. L. 96-596, 94 Stat. 3469, was enacted which corrected jurisdictional defects in sec. 4942(b) found by this Court in H. Fort Flowers Foundation, Inc. v. Commissioner, 72 T.C. 399 (1979), appeal dismissed, and Adams v. Commissioner, 72…
1Opinion of the Court
The Barth Foundation, Petitioner 1 v. Commissioner of Internal Revenue, Respondent
Barth Foundation v. Commissioner
Docket Nos. 19101-80, 19103-80
United States Tax Court
77 T.C. 1008; 1981 U.S. Tax Ct. LEXIS 36;
October 29, 1981, Filed
On May 14, 1980, respondent mailed two notices of deficiency to petitioner in which he determined first tier and second tier excise taxes under sec. 4942(a) and 4942(b), I.R.C. 1954, as amended, for failure to distribute in 1974 and 1975 income earned in 1973 and 1974. On Oct. 14, 1980, petitions were filed disputing those determinations. On Dec. 24, 1980, Pub. L.…
2Cases cited9 opinions
- Graham & Foster v. GoodcellSupreme Court of the United States · 1931
- Adams v. CommissionerUnited States Tax Court · 1979
- Adams v. CommissionerUnited States Tax Court · 1978
- McCue v. CommissionerUnited States Tax Court · 1943
- American Found. Co. v. CommissionerUnited States Tax Court · 1943
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