Ma-Tran Corp. v. Commissioner
United States Tax Court
A major portion of the assets of petitioner corporation's profit-sharing trust were lent to an employee, a trustee, and the corporation. The interest of a plan participant who died while employed by the corporation was not disbursed. The vested interests of persons who terminated employment were treated as forfeitures. Held, the profit-sharing trust is not qualified.
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A major portion of the assets of petitioner corporation's profit-sharing trust were lent to an employee, a trustee, and the corporation. The interest of a plan participant who died while employed by the corporation was not disbursed. The vested interests of persons who terminated employment were treated as forfeitures. Held, the profit-sharing trust is not qualified. Held, further, petitioner corporation did not comply with the substantiation requirements of sec. 274 with respect to use of an apartment, meals, or the travel expenses in issue. Held, further, these amounts constitute dividends…
1Opinion of the Court
Sterrett, Judge:
Respondent, on November 11, 1975, issued statutory notices in which he determined deficiencies in, and additions to, the respective petitioners’ Federal income taxes as follows:
Additions to tax
Petitioner Year Deficiency sec. 6653(a)
Ma-Tran Corp.FYE 6/30/72 $12,160.27 $608.01
FYE 6/30/73 14,635.67 731.78
Andy B. House .1971 308.10
1972 1,010.08
1973 754.68
Walter D. Huffaker .1971 1,037.40
Walter D. and
Lois Simpson Huffaker .1972 3,728.80
1973 4,152.81
Due to concessions made by the parties the following issues remain for our determination: (1) Whether the Ma-Tran Corp. profit-sharing…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Enoch v. CommissionerUnited States Tax Court · 1972
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Commissioner v. KowalskiSupreme Court of the United States · 1977
- Sutter v. CommissionerUnited States Tax Court · 1953
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