§2003

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

ses ofthis acquisition were: (1) to recapture for SDI the commissions 3An ESOP is a tax-exempt plan that invests primarily in the securities ofits sponsoring employer. See Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, sec. 2003(e)(7), 88 Stat. at 976 (codified as amended at sec. 4975(e)(7)). - 5 - [*5] it had been paying Comtrad, (2) to achieve greater vertical integration and control over product sourcing in Asia, (3) to give SDI control ofcertain trademarks held

nes for electronic filings with the hope that the IRS would achieve 80% electronic filing by 2007. See H. Conf. Rept. No. 105-599, at 234-235 (1998), 1998-3 C.B. 747, 988-989; S. Rept. No. 105-174, at 39-42 (1998), 1998-3 C.B. 537, 575-578. RRA 1998 sec. 2003(a)(2), 112 Stat. at 724, amended section 6061 by adding subsection (b). The Secretary thereby is required to develop procedures for the acceptance ofsignatures in digital or other electronic form; and until such time as such procedures are

o this Court * * * since the change d[id] not apply" to the 1980-1981 tax years at issue. M - 31 - The next wave ofcases addressed section 2032A, enacted in 1976, which provided beneficial estate tax treatment for certain farm property. See TRA '76 sec. 2003, 90 Stat. at 1856. Section 2032A(g) provided (and still provides): "The Secretary shall prescribe regulations setting forth the application ofthis section * * * in the case ofan interest in a partnership, corporation, or trust which, with re

2003(a), 88 Stat. 971. Congress enacted section 4975 to effect its intent to tax disqualified 1(...continued) 4975(f)(1). - 11 - persons who engage in self-dealing rather than penalize innocent employees, who were previously faced with plan disqualification on account of a prohibited transaction. S. Rept. 93-383, at 94-95 (1973), 1974-3 C.B.

- 19 - Section 4975¹°, enacted by section 2003(a) of ERISA '74, imposes taxes on a disqualified person who participates in a ¹° Sec.

he additions to tax under section 6651(a)(1). Discussion I. Liability Under Section 4975 A. The Statutes Section 4975 was added to the Internal Revenue Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971. ERISA was enacted to protect * * * the interests of participants in employee benefit plans and their beneficiaries, by requiring the disclosure and reporting to participants and beneficiaries of financial and other inform

1520, 1856. The - 20 - purpose of the special use valuation provision is to reduce the estate tax burden, thereby alleviating liquidity problems faced by the surviving family of a person who died owning real property used as a farm or in a closely held business. See H. Rept. 94- 1380, at 21-22 (1976), 1976-3 C.B. (Vol. 3) 735,

atute of limitations issue, the Commissioner in the instant case determined that the form filed by petitioner is not a return. 3 Sec. 6061(b) was enacted as part of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 2003(a)(1), 112 Stat. 685, 724, effective on July 22, 1998. It is not clear for what taxable years the statute authorizes the Secretary to waive signature requirements for electronic filings. The legislative history suggests that the authority ma

2003(a), 88 Stat. 829, 971. See also Commissioner v. Keystone Consol. Indus., Inc., 508 U.S. at 160 (section 4975(c)(1)(A) contains "broad language"). The Congress enacted section 4975 to effectuate its intent to tax disqualified persons who engage in self-dealing rather than innocent employees who were previously faced with plan disqualificat

st use of real property may coincide with its special use, as here, does not preclude special use valuation under section 2032A. Sec. 20.2032A-3(a), Estate Tax Regs. Section 2032A was added to the Code by the Tax Reform Act of 1976, Pub. L. 94-455, sec. 2003, 90 Stat. 1520, 1856. The purpose of the special valuation provision is to reduce the estate tax burden, thereby alleviating liquidity problems faced by the surviving family of a person who dies owning real property used as a farm or in a cl

1520, 1856. The purpose of the special valuation provision is to reduce the estate tax burden, thereby alleviating liquidity problems faced by the surviving family of a person who dies owning real property used as a farm or in a closely held business. H. Rept. 94-1380 at 21-22 (1976), 1976-3 C.B. (Vol. 3) 735, 755-756; S. Rept.

Court, the parties engaged in negotiations prior to the start of this session in an attempt to resolve the fair market value of the Ranch. During these negotiations Executrix never mentioned 2 Enacted by the Tax Reform Act of 1976, Pub. L. 94-455, sec. 2003, 90 Stat. 1856, primarily to encourage the continued operation of family farms, sec. 2032A permits qualified real property to be valued for estate tax purposes by reference to its use in the farming activity, rather than at its value based o