Legal Opinion

Lambos v. Commissioner

United States Tax Court

Decided June 1, 1987No. Docket No. 34318-83PublishedCited by 13 opinions

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…

2Cases cited9 opinions

  1. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
  2. United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
  3. Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  4. Scar v. CommissionerUnited States Tax Court · 1983
  5. Durbin Paper Stock Co. v. CommissionerUnited States Tax Court · 1983

4 more not listed; retrieve them via the Exa API.

3Cited by13 opinions

  1. Rutland v. CommissionerUnited States Tax Court · 1987
  2. Thoburn v. CommissionerUnited States Tax Court · 1990
  3. Janpol v. CommissionerUnited States Tax Court · 1993
  4. Wood v. CommissionerUnited States Tax Court · 1990
  5. Zabolotny v. CommissionerUnited States Tax Court · 1991

8 more not listed; retrieve them via the Exa API.

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