Citrus Valley Estates v. Commissioner
United States Tax Court
Ps are small businesses engaged in a variety of activities. Ps each adopted small defined benefit plans for one or two key employees. Each plan created a trust to provide for the investment and administration of plan assets.
Read the full summary
Ps are small businesses engaged in a variety of activities. Ps each adopted small defined benefit plans for one or two key employees. Each plan created a trust to provide for the investment and administration of plan assets. For the taxable years at issue, all contributions to the plans were made within the time required by sec. 401(a)(1) and (6), and each of the plans and related trusts was qualified under sec. 401(a) and was exempt from taxation under sec. 501(a). The appropriate Forms 5500 and Schedules B were filed with the Service. R challenged various funding assumptions made by the…
1Opinion of the Court
TABLE OF CONTENTS
Page
Factual Background . 383
Law . 397
Certifying Actuaries . 406
Experts . 407
Interest Rate Background. 409
Petitioners’ Expert . 413
Long-Term Rates of Return . 413
Adjustments for Plan Size . 415
Pre-retirement Adjustments . 416
Post-retirement Adjustments. 417
Comparison to Actuarial Experience . 418
Regulatory and Legal Guidance . 419
Conclusion. 420
Respondent’s Actuarial Expert . 420
Discussion. 421
Retirement Age General Background and Retirement Trends. 428
Segregation Provisions . 430
Davis . 431
Lear . 432
Stephan. 433
Fox. 435
Brody Enterprises . 436
Mortality Assumptions Citrus…
2Cases cited6 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Mailman v. CommissionerUnited States Tax Court · 1988
- Martin Fireproofing Profit-Sharing Plan & Trust v. CommissionerUnited States Tax Court · 1989
- Jerome Mirza & Associates, Ltd., an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1989
1 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Estate of Jung v. CommissionerUnited States Tax Court · 1993
- Price v. CommissionerUnited States Tax Court · 1994
- Rhoades, McKee, & Boer v. United StatesDistrict Court, W.D. Michigan · 1993
- Flahertys Arden Bowl, Inc. v. CommissionerUnited States Tax Court · 2000
- Citrus Valley Estates, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 1995
17 more not listed; retrieve them via the Exa API.