Janpol v. Commissioner
United States Tax Court
Ps were held liable for sec. 4975(a), I.R.C., excise taxes on prohibited transactions in an earlier opinion, Janpol v. Commissioner, 101 T.C. 518 (1993). Held, Ps are liable for sec. 6651(a)(1) additions to tax for failure to file excise tax returns.
1Opinion of the Court
Arthur S. Janpol, Petitioner v. Commissioner of Internal Revenue, Respondent; * Donald Berlin, Petitioner v. Commissioner Internal Revenue, Respondent
Janpol v. Commissioner
Docket Nos. 5586-92, 5587-92
United States Tax Court
102 T.C. 499; 1994 U.S. Tax Ct. LEXIS 18; 102 T.C. No. 17; 17 Employee Benefits Cas. (BNA) 2515;
March 28, 1994, Filed
Decisions will be entered under Rule 155.
Ps were held liable for sec. 4975(a), I.R.C., excise taxes on prohibited transactions in an earlier opinion, Janpol v. Commissioner, 101 T.C. 518 (1993). Held, Ps are liable for sec. 6651(a)(1) additions to tax for…
2Cases cited15 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Beard v. Comm'rUnited States Tax Court · 1984
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
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