Janpol v. Commissioner
United States Tax Court
Ps, disqualified persons, lent money and guaranteed bank loans to a pension trust. Held, Ps are liable for sec. 4975(a), I.R.C., excise taxes on prohibited transactions, in the amounts computed by R.
1Opinion of the Court
Arthur S. Janpol, Petitioner v. Commissioner of Internal Revenue, Respondent; Donald Berlin, Petitioner v. Commissioner of Internal Revenue, Respondent
Janpol v. Commissioner
Docket Nos. 5586-92, 5587-92
United States Tax Court
101 T.C. 518; 1993 U.S. Tax Ct. LEXIS 75; 101 T.C. No. 34; 17 Employee Benefits Cas. (BNA) 1873;
December 7, 1993, Filed
Ps, disqualified persons, lent money and guaranteed bank loans to a pension trust. Held, Ps are liable for sec. 4975(a), I.R.C., excise taxes on prohibited transactions, in the amounts computed by R.
John N. Lieuwen and Patricia Tucker, for petitioners.
Thoma…
2Cases cited11 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. Keystone Consolidated Industries, Inc.Supreme Court of the United States · 1993
- Rutland v. CommissionerUnited States Tax Court · 1987
- Thoburn v. CommissionerUnited States Tax Court · 1990
- Leib v. CommissionerUnited States Tax Court · 1987
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