Rutland v. Commissioner
United States Tax Court
M Corp. maintained a retirement plan for the benefit of its employees. Ps were officers, directors, and employees of M Corp. and participants in such plan. In 1976, Ps sold property owned by them to the plan for $ 430,000. The plan paid cash, assumed an outstanding mortgage on the property, and issued a promissory note to Ps as consideration for the purchase. In 1977, the plan leased such property to M Corp. for use as its corporate headquarters.
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M Corp. maintained a retirement plan for the benefit of its employees. Ps were officers, directors, and employees of M Corp. and participants in such plan. In 1976, Ps sold property owned by them to the plan for $ 430,000. The plan paid cash, assumed an outstanding mortgage on the property, and issued a promissory note to Ps as consideration for the purchase. In 1977, the plan leased such property to M Corp. for use as its corporate headquarters. The plan failed to report such transactions as prohibited transactions under sec. 4975(c), I.R.C. 1954. In 1978, Ps filed an application for…
1Opinion of the Court
SIMPSON, Judge:
The Commissioner determined identical deficiencies in each of the individual petitioner’s Federal excise taxes as follows:
Year Deficiency
1976 $21,508.32
1977 23,028.47
1978 24,548.62
1979 25,426.67
1980 24,131.43
1981 21,500.00
The Commissioner also determined a deficiency in the Federal excise taxes of petitioner Matthews-McCracken-Rutland Corp. as follows:
TYE May 31-Deficiency
1977. $750
1978. 2,550
1979. 4,350
1980. 6,150
1981. 6,150
The issues for our decision are: (1) Whether the sale of property by the individual petitioners to an employee stock bonus plan and the subsequent lease of…
2Cases cited21 opinions
- Beard v. Comm'rUnited States Tax Court · 1984
- Donovan v. CunninghamCourt of Appeals for the Fifth Circuit · 1983
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
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