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Tax Cases

Tax Cases

Highlights of various tax cases.
Albrecht v. United States
Ms. Albrecht, age 83, transferred a significant number of shares of Beneficial Finance Company to her family members and died within three years.
Benson v. Commissioner
Mr. Benson established a ten-year trust and transferred to it a building which his corporation then leased.
Bielfeldt v. Commissioner of IRS
Mr. Bielfeldt and his partnership claimed to be a dealer rather than an investor with respect to government securities and were thus entitled to ordinary vs. capital losses generated from his activities.
Brady v. United States
Mr. Brady, a self-employed contractor, engaged individuals to provide construction services on his behalf as independent contractors.
Custom Builders, Inc. v. Commissioner of the IRS
Custom Builders adopted a defined benefit plan. The plan actuary determined the plan’s normal cost using an interest rate assumption of 5%.
D.J. Mahoney Co. v. Commissioner
The Internal Revenue Service contended that the taxpayer had accumulated profits in excess of accumulations
DMI Inc. v. Commissioner
The taxpayer paid its principal shareholder and key employee compensation determined by reference to the year-end profits of the employer-corporation.
Estate of Sauder v. Commissioner
The decedent died owning multiple classes of voting and non-voting preferred; each class carried non-cumulative dividends.
Fort Transfer Co. v. United States
The taxpayer paid its principal shareholder and key employee compensation determined by reference to the year-end profits of the employer-corporation.
Hartman v. United States
Mrs. Hartmann made gifts of shares of a close-held corporation to her son and grandchildren.
Hillyer Excavating Service v. Commissioner
The taxpayer contended that the subject transaction qualified for “like-kind” treatment given the use of a qualified intermediary.
Jerome Mirza & Associates, Ltd. v. United States
The taxpayer, a professional corporation established by a well-regarded personal injury lawyer, established a defined benefit pension plan.
Lloyd Schumacher Chevrolet-Buick, Inc. v. United States
The taxpayer paid its principal shareholder and key employee compensation determined by reference to the year-end profits of the employer-corporation.
Medical Radiological Group, P.C. v. Commsissioner
The taxpayer established multiple defined benefit pension plans, one for each of its shareholders, with varying normal retirement date provisions.
Mueller v. Commissioner
The taxpayer successfully concluded an Age Discrimination case and bargained for and received a single premium deferred variable annuity, the ownership of which remains in the defendant.
People v. O'Neill
Mr. O’Neill contended that the then current Illinois Personal Property Tax was invalid
St. John v. United States
The taxpayer sold interests in a general partnership formed to construct a nursing home and received a subordinated profits interest in the partnership.
United States v. Commercial National Bank of Peoria
The taxpayer died owning shares of the corporation. The value of the shares was contested by the decedent’s estate and the Internal Revenue Service.
United States v. Hemme
Prior to 1977, a taxpayer was allowed a lifetime exemption of $30,000 to be deducted from amounts otherwise taxable, which exemption could be claimed anytime during the taxpayer’s lifetime.
Yeomans Distributing Co. v. United States
The taxpayer established a non-qualified deferred compensation plan for the benefit of its controlling shareholder, the father of one of its minority shareholders, and thereafter, for the benefit of the father’s surviving spouse.
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