Janpol v. Commissioner
United States Tax Court
Ps were held liable for sec. 4975(a), I.R.C., excise taxes on prohibited transactions in an earlier opinion, Janpol v. Commissioner, 101 T.C. 518 (1993). Held, Ps are liable for sec. 6651(a)(1) additions to tax for failure to file excise tax returns.
1Opinion of the Court
SUPPLEMENTAL OPINION
COHEN, Judge-.
In Janpol v. Commissioner, 101 T.C. 518 (1993), we held that petitioners were liable for section 4975(a) excise taxes on prohibited transactions. We incorporate and rely on the findings of fact set forth in that opinion. Briefly, we held that petitioners’ loans to the Imported Motors Profit Sharing Trust (the trust) were prohibited transactions giving rise to excise tax liability in accordance with respondent’s method of computation. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all…
2Cases cited14 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Beard v. Comm'rUnited States Tax Court · 1984
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
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3Cited by7 opinions
- Oman v. Comm'rUnited States Tax Court · 2010
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- Mendes v. Comm'rUnited States Tax Court · 2003
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