Woodson v. Commissioner

73 T.C. 779, 1980 U.S. Tax Ct. LEXIS 194
CourtUnited States Tax Court
DecidedFebruary 5, 1980
DocketDocket No. 646-79
StatusPublished
Cited by16 cases

This text of 73 T.C. 779 (Woodson v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Woodson v. Commissioner, 73 T.C. 779, 1980 U.S. Tax Ct. LEXIS 194 (tax 1980).

Opinions

OPINION

Sterrett, Judge:

In a notice of deficiency dated October 6, 1978, respondent determined a deficiency in the income taxes paid by petitioners for their taxable years ended December 31, 1970 and 1971, in the amounts of $512.34 and $6,491.60, respectively. After concessions, the only remaining issue for our decision is whether that part of the net distribution, which was received from a profit-sharing trust not qualified or exempt under sections 401(a) and 501(a), I.R.C. 1954, that is attributable to contributions made to the trust in years when it was qualified, should be taxed as ordinary income or as long-term capital gain.

This case was submitted under Rule 122, Tax Court Rules of Practice and Procedure. Hence, all of the facts have been stipulated and are so found.

Curtis B. Woodson resided in Corpus Christi, Tex., at the time the petition was filed herein. Curtis B. Woodson and Fern R. Woodson (petitioners) were husband and wife until the death of Fern R. Woodson on November 3, 1971. Curtis B. Woodson was appointed independent executor of the Estate of Fern R. Woodson, deceased. Petitioners filed their joint Federal income tax return for 1971 with the Director, Internal Revenue Service Center, Austin, Tex.

Curtis B. Woodson and Edna Woodson, married in 1973, filed joint income tax returns for 1973 and 1974 with the Director, Internal Revenue Service Center, Austin, Tex. On or .about May 6, 1974, Curtis B. Woodson filed an application for tentative refund (Form 1045) claiming a refund of $33.01 for taxable year 1971 based on the carryback of unused investment credit in that amount from taxable year 1973.

On or about March 3, 1975, Curtis B. Woodson filed an application for tentative refund (Form 1045), claiming a refund of $41,388.96 for taxable year 1971 based on claimed operating loss carryback from 1974 to taxable year 1971. On or about May 22, 1974, and March 13, 1975, petitioners received refunds of their 1971 taxes in the amounts of $33.01 and $41,388.96, respectively, for a total tentative allowance of $41,421.97 for the 1971 taxable year.

In 1974, Curtis B. and Edna Woodson received a net lump-sum distribution from the profit-sharing trust of Gibson Products Co. of Corpus Christi, Inc., in the amount of $25,485.98 (total distribution of $30,052.81 less employees’ contributions of $4,566.83). This distribution represented their entire interest in the trust.

Gibson Products Co. of Corpus Christi, Inc. (hereinafter Gibson Products), a small business corporation, was incorporated in April 1961 and had a fiscal year ending March 31. Curtis B. Woodson was president of the corporation during all years relevant to this case. The corporation was liquidated as of December 27, 1974. As of that date, the shareholders were as follows:

Curtis B. Woodson . 226 shares
Estate of Fern R. Woodson, deceased . 283 shares
Curtis B. Woodson as custodian for David Woodson . 56 shares

David Woodson is petitioners’ son.

The corporation had a profit-sharing trust from 1966 until September 9, 1974, when the trust was terminated. Curtis B. Woodson and Edna Woodson were each members of the profit-sharing trust. The profit-sharing trust was qualified under section 401(a) from 1966 until April 1,1973, the effective date of the revocation of its exempt status by respondent. Petitioners do not contest the revocation of its exempt status. The revocation letter, dated July 30, 1975, from the Office of the District Director of Internal Revenue, Austin, Tex., to Gibson Products stated in part: “In view of the fact that benefits were forfeited on partial termination of the plan and funds were diverted to purposes other than for the exclusive benefit of the participants, our determination letters referred to above are hereby revoked, effective April 1,1973.”

Of the net distribution of $25,485.98 received by petitioners, $2,643.39 was attributable to contributions to the trust made during the period of time following the loss of its exempt status until its termination on September 9,1974.

In 1974, Curtis B. and Edna Woodson received a net lump-sum distribution from the Gibson Products Co. profit-sharing trust of $25,485.98, which represented their entire interest in the trust. The only issue before the Court is whether any part of the distribution was from a qualified trust. The tax stakes are clear. If the distribution is deemed from a qualified trust exempt from tax under sections 401(a) and 501(a), I.R.C. 1954, then section 402(a)(2)1 allows petitioners to characterize the income as long-term capital gain. That part of the distribution which is from a nonqualified trust is controlled by section 402(b)2 which treats it as ordinary income.

Petitioners concede that the part of the distribution which represents contribution to the trust following the loss of its exempt status ($2,643.39) is a distribution from a nonqualified plan and is ordinary income. Petitioners, citing the Second Circuit's decision in Greenwald v. Commissioner, 366 F.2d 538 (2d Cir. 1966), revg. in part 44 T.C. 137 (1965), argue that, although the $2,643.39 should be taxed as ordinary income in 1974, the remaining $22,842.59 of the net distribution should be treated as a distribution from a qualified plan and therefore taxed as long-term capital gain.3

Eespondent argues that, since the plan and its related trusts were nonexempt in the year of distribution, this Court’s decisions in Greenwald v. Commissioner, supra, and Epstein v. Commissioner, 70 T.C. 439 (1978), require the distribution be taxed as ordinary income under section 402(b). In Greenwald v. Commissioner, we found that the profit-sharing plan in issue was not exempt at the time the distribution was made in 1959 and held that the entire distribution was taxable as ordinary income pursuant to section 402(b). On appeal, the Court of Appeals for the Second Circuit agreed that the plan was nonexempt, but reversed in part the decision of this Court and held that the distribution attributable to contributions made to the plan during the time it was qualified under section 401(a) was taxable as capital gain under section 402(a)(2).

The possibility of taxing the trust distribution partly as capital gain and partly as ordinary income was not argued in this Court by the parties in Greenwald. Only on appeal, and then only in supplemental briefs submitted at the behest of the Court of Appeals, was that result considered. In that sense, we face that issue for the first time.4

Who did what, is obviously a relevant question in determining whether a plan has lost its exempt status. It is not a relevant question, in consideration of the issue, whether a distribution must be taxed as all ordinary income or part ordinary income and part capital gain, since the distribution should be taxed the same whether the recipient is the one who caused the disqualification by some misfeasance or is an innocent lower-echelon employee.

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Woodson v. Commissioner
73 T.C. 779 (U.S. Tax Court, 1980)

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Bluebook (online)
73 T.C. 779, 1980 U.S. Tax Ct. LEXIS 194, Counsel Stack Legal Research, https://law.counselstack.com/opinion/woodson-v-commissioner-tax-1980.