Griffin v. Commissioner, T.C. Memo 2011-61 (2011)
N/AOUTCOME: The United States Tax Court ruled in Taxpayer's favor, plus IRS paid $180,000 in attorney fees.
$5,000,000 IRS transferee liability case
Des Moines, IA
Tax Lawyer at Des Moines, IA
Practice Areas: Tax, Probate ... +2 more
OUTCOME: The United States Tax Court ruled in Taxpayer's favor, plus IRS paid $180,000 in attorney fees.
$5,000,000 IRS transferee liability case
OUTCOME: The United States Tax Court ruled the ESOP did qualify and ruled against the IRS on other grounds.
The IRS challenged the qualification of an ESOP for numerous grounds – failure to timely amend a plan, failure to use an independent appraiser and overfunding the ESOP.
OUTCOME: The United States Tax Court ruled that the corporation did not have to pay compensation to the employee/shareholder because amount were actually repayments of loans.
The IRS attempted to assess taxes against the corporation for not paying compensation to its S Corporation shareholder employee, even though the corporation lost substantial sums of money.
OUTCOME: The Court ruled that there was no cancellation of indebtedness income.
The IRS was seeking cancellation of indebtedness income from a former NFL player.