Feichtinger v. Commissioner
United States Tax Court
Petitioner, administrator of a defined benefit pension plan, seeks judgment, pursuant to sec. 7476, I.R.C. 1954, declaring that respondent's adverse determination letter with respect to qualification of the plan under sec. 401, I.R.C. 1954, is erroneous.
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Petitioner, administrator of a defined benefit pension plan, seeks judgment, pursuant to sec. 7476, I.R.C. 1954, declaring that respondent's adverse determination letter with respect to qualification of the plan under sec. 401, I.R.C. 1954, is erroneous. Respondent's adverse determination letter is based on certain plan language prescribing anticipation of cost-of-living increases as a basis for the actuarial assumptions by which a current year's contributions are determined. Held, respondent's determination is based upon correct application of valid criteria for disqualification of defined…
1Opinion of the Court
James N. Feichtinger, Petitioner v. Commissioner of Internal Revenue, Respondent
Feichtinger v. Commissioner
Docket No. 26756-81 "R."
United States Tax Court
80 T.C. 239; 1983 U.S. Tax Ct. LEXIS 125; 80 T.C. No. 4; 4 Employee Benefits Cas. (BNA) 1001;
January 20, 1983, Filed
Petitioner, administrator of a defined benefit pension plan, seeks judgment, pursuant to sec. 7476, I.R.C. 1954, declaring that respondent's adverse determination letter with respect to qualification of the plan under sec. 401, I.R.C. 1954, is erroneous. Respondent's adverse determination letter is based on certain plan…
2Cases cited9 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Thompson v. CommissionerUnited States Tax Court · 1978
- Washington v. CommissionerUnited States Tax Court · 1981
- State of Washington v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1982
- BBS Associates, Inc. v. CommissionerUnited States Tax Court · 1980
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