Chapman v. Commissioner
United States Tax Court
P, an employee of Blue Cross/Blue Shield of Massachusetts was covered by his employer's qualified pension plan. Participants in the plan received benefits keyed to their years of credited service. P became eligible to participate in the plan in July 1974. P accrued benefits under the plan from Jan. 1, 1976, through Aug. 31, 1976, and was credited with 1,301 hours during that period.
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P, an employee of Blue Cross/Blue Shield of Massachusetts was covered by his employer's qualified pension plan. Participants in the plan received benefits keyed to their years of credited service. P became eligible to participate in the plan in July 1974. P accrued benefits under the plan from Jan. 1, 1976, through Aug. 31, 1976, and was credited with 1,301 hours during that period. The plan provides that an employee has completed a year of service if he completes at least 1,000 hours of service during the plan year. P was entitled to reinstatement of previously accrued benefits if reemployed…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge James M. Gussis pursuant to section 7456(c), I.R.C. 1954,1 and Rules 180 and 181 of the Tax Court Rules of Practice and Procedure.2 The Court agrees with and adopts his opinion which is set forth below.
OPINION OF SPECIAL TRIAL JUDGE
Gussis, Special Trial Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for 1976 in the amount of $540 and also determined an excise tax deficiency for 1976 in the amount of $90. The case was submitted to the Court fully stipulated. Rule 122. The issues are (1) whether a…
2Cases cited3 opinions
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- John F. Foulkes and Joyce A. Foulkes v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1981
3Cited by21 opinions
- Horvath v. CommissionerUnited States Tax Court · 1982
- Eanes v. CommissionerUnited States Tax Court · 1985
- Porter v. CommissionerUnited States Tax Court · 1987
- Hauser v. Comm'rUnited States Tax Court · 1982
- Orvis v. CommissionerUnited States Tax Court · 1984
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