- 2 -
Taxable Year Income Tax Excise Tax Additions to Tax
Ending Deficiency Deficiency Sec. 6651 Sec. 6659A
9/30/87 $61,816 -- -- $18,555
9/30/88 55,075 $22,679 $ 5,670 16,523
9/30/89 52,970 45,359 11,340 15,891
9/30/90 -- 45,359 11,340 --
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After settlement of some issues, the issue for decision is
whether petitioner's contributions to its employee benefit plans
exceeded the actuarial costs of funding retirement benefits
provided under the plans.
Background
This case was submitted fully stipulated by the parties
pursuant to Rule 122. When the petition was filed, petitioner's
principal place of business was located in New York, New York.
During the years in issue, Chaim Rozenblatt and Adam
Jakubowicz each owned 50 percent of the stock of petitioner.
On July 1, 1987, petitioner adopted two defined benefit
pension plans (the plans) -- one for the benefit of Rozenblatt
and one for the benefit of Jakubowicz. The plans were drafted by
Morris J. Silberstein, an actuary with Pensions & Forecasting Co.
The plans were effective retroactively as of October 1, 1986.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011