Elliot Knitwear Profit Sharing Plan v. Commissioner
United States Tax Court
Petitioner is the trustee of a qualified profit sharing plan. Pursuant to his authority as trustee, petitioner purchased securities on margin for the trust account. The purchases were made for the exclusive benefit of plan participants and their beneficiaries.
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Petitioner is the trustee of a qualified profit sharing plan. Pursuant to his authority as trustee, petitioner purchased securities on margin for the trust account. The purchases were made for the exclusive benefit of plan participants and their beneficiaries. Respondent determined that the securities were debt-financed property under sec. 514, I.R.C. 1954, 1Unless otherwise stated, all statutory references are to the Internal Revenue Code of 1954, as in effect for the taxable year at issue. and that the income earned on those securities was taxable under sec. 511 to the extent of the…
1Opinion of the Court
Elliot Knitwear Profit Sharing Plan, Louis M. Lempke, Trustee by Herman Gross, Substitute Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Elliot Knitwear Profit Sharing Plan v. Commissioner
Docket No. 2725-77
United States Tax Court
71 T.C. 765; 1979 U.S. Tax Ct. LEXIS 175;
February 12, 1979, Filed
Decision will be entered for the respondent.
Petitioner is the trustee of a qualified profit sharing plan. Pursuant to his authority as trustee, petitioner purchased securities on margin for the trust account. The purchases were made for the exclusive benefit of plan participants and…
2Cases cited4 opinions
- Groetzinger v. CommissionerUnited States Tax Court · 1977
- Driscoll v. Washington County Fire Ins.Court of Appeals for the Third Circuit · 1940
- Rowley United Pension Fund v. CommissionerUnited States Tax Court · 1975
- Elliot Knitwear Profit Sharing Plan v. CommissionerUnited States Tax Court · 1979