Couturier v. Comm'r

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Full Text of Court Cases
July 6, 2022
2678 Stationery, Tablets, and Related Products
322230 Stationery Product Manufacturing
ESOP valuations, estate and gift taxation, federal taxation
stock, deficiency, employee stock ownership plan (ESOP), income tax, summary judgment

Couturier v. Comm'r
T.C. Memo 2022-69; 2022 Tax Ct. Memo LEXIS 68;124 T.C.M. (CCH) 6
United States
Federal Court
Federal
United States Tax Court
Lauber

Summary

The Tax Court was asked in this ESOP-related case to approve the taxpayer’s motion for summary judgment. The petitioner contended that the IRS “is precluded as a matter of law from asserting excise tax liability under section 4973” because it did not issue him a notice of deficiency challenging his income tax treatment of the transactions that generated the excess contributions. The motion was denied. The alleged excess contributions were more than $26 million with alleged excise tax of more than $8 million.
T.C. Memo (Couturier)
PDF, Size: 149 KB

See Also

Tax Court Denies Taxpayer’s Motion for Summary Judgment Relative to an Excess IRA Contribution Relating to an ESOP Purchase/Sale

The Tax Court was asked in this ESOP-related case to approve the taxpayer’s motion for summary judgment. The petitioner contended that the IRS “is precluded as a matter of law from asserting excise tax liability under section 4973” because it did not issue him a notice of deficiency challenging his income tax treatment of the transactions that generated the excess contributions. The motion was denied. The alleged excess contributions were more than $26 million with alleged excise tax of more than $8 million.