Garland v. Commissioner
United States Tax Court
Petitioner, a professional medical corporation, formed a partnership with a doctor. Each partner owned a 50-percent interest in the partnership. The corporation adopted a pension plan which did not cover the employees of the partnership. Petitioner was not required by either sec. 414(b), I.R.C. 1954, or sec. 414(c), I.R.C. 1954, to cover the partnership employees under the plan.
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Petitioner, a professional medical corporation, formed a partnership with a doctor. Each partner owned a 50-percent interest in the partnership. The corporation adopted a pension plan which did not cover the employees of the partnership. Petitioner was not required by either sec. 414(b), I.R.C. 1954, or sec. 414(c), I.R.C. 1954, to cover the partnership employees under the plan. Nevertheless, respondent determined that the plan did not qualify under sec. 401(a), I.R.C. 1954, because it did not comply with the antidiscrimination provisions of secs. 401(a)(4) and 410(b)(1), I.R.C. 1954. Held,…
1Opinion of the Court
Lloyd M. Garland, M.D., F.A.C.S., P.A., Petitioner v. Commissioner of Internal Revenue, Respondent
Garland v. Commissioner
Docket No. 9956-78R
United States Tax Court
73 T.C. 5; 1979 U.S. Tax Ct. LEXIS 44; 1 Employee Benefits Cas. (BNA) 1614;
October 4, 1979, Filed
Petitioner, a professional medical corporation, formed a partnership with a doctor. Each partner owned a 50-percent interest in the partnership. The corporation adopted a pension plan which did not cover the employees of the partnership. Petitioner was not required by either sec. 414(b), I.R.C. 1954, or sec. 414(c), I.R.C. 1954, to cover…
2Cases cited7 opinions
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Packard v. CommissionerUnited States Tax Court · 1975
- Max A. Burde and Berthe C. Burde v. Commissioner of Internal Revenue, Bernard Weiss and Peggy S. Weiss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Moradian v. CommissionerUnited States Tax Court · 1969
- Burnetta v. CommissionerUnited States Tax Court · 1977
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