Lambos v. Commissioner
United States Tax Court
K corporation maintained a profit-sharing plan for employees during the years at issue. A, an individual, owned 50 percent or more of the combined voting power of all classes of stock entitled to vote or the total value of shares of all classes of stock of K corporation. O is the spouse of A. A and O entered into lease transactions with the profit-sharing plan maintained by K corporation. Held, A and O are disqualified persons.
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K corporation maintained a profit-sharing plan for employees during the years at issue. A, an individual, owned 50 percent or more of the combined voting power of all classes of stock entitled to vote or the total value of shares of all classes of stock of K corporation. O is the spouse of A. A and O entered into lease transactions with the profit-sharing plan maintained by K corporation. Held, A and O are disqualified persons. Held, further, the subject lease transactions are prohibited transactions. Held, further, the amount involved is determined by considering the subject lease…
1Opinion of the Court
OPINION
HAMBLEN, Judge:
Respondent determined deficiencies of excise tax imposed under section 4975(a)1 as follows:
Petitioner TYE Deficiency
Olga Lambos (Olga) 1976 1977 1978 1979 1980 1981 $228.00 684.00 1,140.00 1,596.00 2,052.00 2,508.00
Anton Lambos (Anton) and Olga Lambos 1976 1977 1978 1979 1980 1981 487.50 975.00 1.462.50 1,950.00 2.437.50 2,925.00
The issues for decision are (1) whether petitioners are disqualified persons within the meaning of section 4975(e)(2); (2) whether certain lease transactions were prohibited transactions within the meaning of section 4975(c); and (3) whether the…
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