Ludden v. Commissioner
United States Tax Court
Held, uncorrected inadvertent failure of a corporation to contribute to trusts which were part of pension and profit-sharing plans on behalf of its only employee eligible under the plans other than the shareholder-officers, who were highly compensated, caused the plans and trusts to fail to qualify under sec. 401(a), I.R.C. 1954, for the year of such failure even though the plans by their terms met the requirements of sec. 401(a), I.R.C. 1954. Held, further, contributions to…
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Held, uncorrected inadvertent failure of a corporation to contribute to trusts which were part of pension and profit-sharing plans on behalf of its only employee eligible under the plans other than the shareholder-officers, who were highly compensated, caused the plans and trusts to fail to qualify under sec. 401(a), I.R.C. 1954, for the year of such failure even though the plans by their terms met the requirements of sec. 401(a), I.R.C. 1954. Held, further, contributions to the trusts made by the corporation on behalf of petitioners, are includable in their taxable income under secs. 402(b)…
1Opinion of the Court
Allen Ludden and Betty White Ludden, Petitioners v. Commissioner of Internal Revenue, Respondent
Ludden v. Commissioner
Docket No. 2992-76
United States Tax Court
68 T.C. 826; 1977 U.S. Tax Ct. LEXIS 55; 1 Employee Benefits Cas. (BNA) 1787;
August 31, 1977, Filed
Decision will be entered for the respondent.
Held, uncorrected inadvertent failure of a corporation to contribute to trusts which were part of pension and profit-sharing plans on behalf of its only employee eligible under the plans other than the shareholder-officers, who were highly compensated, caused the plans and trusts to fail to…
2Cases cited7 opinions
- Aero Rental v. CommissionerUnited States Tax Court · 1975
- Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Quality Brands, Inc. v. CommissionerUnited States Tax Court · 1976
- Ludden v. CommissionerUnited States Tax Court · 1977
- Myrna Myron v. United StatesCourt of Appeals for the Ninth Circuit · 1977
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