Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
United States Tax Court
Ps, profit-sharing trusts qualified under secs. 401(a) and 501(a), I.R.C. 1954, held limited partnership interests in several partnerships engaging in the wholesale fastener distribution business. Held, Ps realized "unrelated business taxable income" within the meaning of sec. 512, I.R.C. 1954, from their distributive shares of income from such partnerships. Held, further, additions to tax under sec. 6651(a)(1), I.R.C. 1954, imposed.
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Ps, profit-sharing trusts qualified under secs. 401(a) and 501(a), I.R.C. 1954, held limited partnership interests in several partnerships engaging in the wholesale fastener distribution business. Held, Ps realized "unrelated business taxable income" within the meaning of sec. 512, I.R.C. 1954, from their distributive shares of income from such partnerships. Held, further, additions to tax under sec. 6651(a)(1), I.R.C. 1954, imposed. Held, further, respondent is not estopped from asserting the deficiencies and additions to tax at issue.
1Opinion of the Court
Service Bolt & Nut Co. Profit Sharing Trust, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
Docket Nos. 1438-80, 1439-80, 1440-80
United States Tax Court
78 T.C. 812; 1982 U.S. Tax Ct. LEXIS 95; 78 T.C. No. 57;
May 20, 1982, Filed
Decisions will be entered for the respondent.
Ps, profit-sharing trusts qualified under secs. 401(a) and 501(a), I.R.C. 1954, held limited partnership interests in several partnerships engaging in the wholesale fastener distribution business. Held, Ps realized "unrelated business taxable…
2Cases cited14 opinions
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- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Heman v. CommissionerUnited States Tax Court · 1959
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