Vinson & Elkins v. Commissioner
United States Tax Court
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
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. NewmanCourt of Appeals for the Second Circuit · 1947
- Jerome Mirza & Associates, Ltd., an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1989
- Jerome Mirza & Associates, Ltd. v. United StatesDistrict Court, C.D. Illinois · 1988
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3Cited by21 opinions
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- Price v. CommissionerUnited States Tax Court · 1994
- Rhoades, McKee, & Boer v. United StatesDistrict Court, W.D. Michigan · 1993
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