Loevsky v. Commissioner
United States Tax Court
Held, the Commissioner's determination of discrimination in the operation of petitioner's pension plan under secs. 401(a)(3)(B) and 401(a)(4) is not arbitrary, unreasonable, or an abuse of discretion, and his determination is therefore sustained.
1Opinion of the Court
Quealy, Judge:
The respondent determined deficiencies in the Federal income taxes due from George Loevsky and Ruth Loevsky, and Louis Loevsky and Faye Loevsky, as follows:
Year Deficiency Docleet No.
1964 $3,953.55 1965 6,222.81 5579-68.
1964 3, 953. 55 1965 6,182.76 5580-68.
Respondent has abandoned the issue as to whether the contributions to the pension plan are not deductible because the plan was not irrevocably created. See Rev. Rul. 60-276,1960-2 C.B. 150. Consequently, the only question presented for decision is whether the eligibility classification established under a corporate pension…
Also in this document: Dissent.
2Cases cited5 opinions
- Inland Steel Co. v. National Labor Relations BoardCourt of Appeals for the Seventh Circuit · 1949
- Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
- Ed & Jim Fleitz, Inc. v. CommissionerUnited States Tax Court · 1968
- Pepsi-Cola Niagara Bottling Corp. v. CommissionerUnited States Tax Court · 1967
- Harrow-Taylor Butter Co. v. CrooksCourt of Appeals for the Eighth Circuit · 1930
3Cited by37 opinions
- Lansons, Inc. v. CommissionerUnited States Tax Court · 1978
- Liberty Machine Works, Inc. v. CommissionerUnited States Tax Court · 1974
- Babst Services, Inc. v. CommissionerUnited States Tax Court · 1976
- Pulver Roofing Co. v. CommissionerUnited States Tax Court · 1978
- Wisconsin Nipple & Fabricating Corp. v. CommissionerUnited States Tax Court · 1976
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