Legal Opinion

Vinson & Elkins v. Commissioner

United States Tax Court

Decided July 14, 1992No. Docket Nos. 12030-90, 12412-91PublishedCited by 21 opinions

P is a general partnership engaged in the practice of law. Effective Sept. 1, 1984, P adopted individual defined benefit plans for a majority of its partners. Each plan created a trust to provide for the investment and administration of the plan assets.

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P is a general partnership engaged in the practice of law. Effective Sept. 1, 1984, P adopted individual defined benefit plans for a majority of its partners. Each plan created a trust to provide for the investment and administration of the plan assets. For the taxable years at issue, 1986 and 1987, all contributions to the plans were made within the time required by sec. 401(a)(1) and (6), and each of the plans and related trusts was qualified under sec. 401(a) and was exempt from taxation under sec. 501(a). The appropriate Forms 5500 and Schedules B were filed with the Service. R challenged…

1Opinion of the Court

TABLE OF CONTENTS

Factual Background . 11

Law . 13

Experts . 21.

Interest Rate . 24

Background. 24

Petitioner’s Actuarial Experts 29

Respondent’s Actuarial Experts . 33

Discussion . 36

Retirement Age . 41

1958 CSO Table for Preretirement Mortality . 49

Postretirement Expense Load. 53

Best Estimate. 56

Tax Motivation. 57

Evidentiary Matters . 58

Conclusion . 59

OPINION

Clapp, Judge:

These consolidated cases are partnership actions for readjustment of partnership items under section 6226. Vinson and Elkins (V&E) is a general partnership engaged in the practice of law. On April 25, 1990, and April 15, 1991,…

2Cases cited6 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. Neuberger v. CommissionerSupreme Court of the United States · 1940
  3. Commissioner of Internal Revenue v. NewmanCourt of Appeals for the Second Circuit · 1947
  4. Jerome Mirza & Associates, Ltd., an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1989
  5. Jerome Mirza & Associates, Ltd. v. United StatesDistrict Court, C.D. Illinois · 1988

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

3Cited by21 opinions

  1. Vinson & Elkins, J. Evans Attwell, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
  2. Bank One Corp. v. Comm'rUnited States Tax Court · 2003
  3. A.E. Staley Mfg. Co. v. CommissionerUnited States Tax Court · 1995
  4. Price v. CommissionerUnited States Tax Court · 1994
  5. Rhoades, McKee, & Boer v. United StatesDistrict Court, W.D. Michigan · 1993

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

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