Legal Opinion

Citrus Valley Estates v. Commissioner

United States Tax Court

Decided September 29, 1992No. Docket Nos. 12900-89, 22599-89, 6505-90, 13406-90, 13407-90, 13449-90, 19117-90, 19654-90, 19716-90, 24352-90, 177-91, 15473-91PublishedCited by 22 opinions

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.

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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

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  3. Mailman v. CommissionerUnited States Tax Court · 1988
  4. Martin Fireproofing Profit-Sharing Plan & Trust v. CommissionerUnited States Tax Court · 1989
  5. 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

  1. Estate of Jung v. CommissionerUnited States Tax Court · 1993
  2. Price v. CommissionerUnited States Tax Court · 1994
  3. Rhoades, McKee, & Boer v. United StatesDistrict Court, W.D. Michigan · 1993
  4. Flahertys Arden Bowl, Inc. v. CommissionerUnited States Tax Court · 2000
  5. Citrus Valley Estates, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 1995

17 more not listed; retrieve them via the Exa API.

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