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HOCKADEN & ASSOCIATES, INC. v. C.I.R.

No. 85-1625.

800 F.2d 70 (1986)

HOCKADEN AND ASSOCIATES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided August 21, 1986.

Rehearing Denied September 22, 1986.

Attorney(s) appearing for the Case

Larry H. Snyder (argued), Chamblin & Snyder, Columbus, Ohio, for petitioner-appellant.

Michael L. Paul (Lead Counsel), Glenn L. Archer, Jr., Tax Division-Dept. of Justice, Roger M. Olsen, Jonathan S. Cohen, David L. Pincus (argued), Washington, D.C., for respondent-appellee.

Before MERRITT and GUY, Circuit Judges and BALLANTINE, District Judge.

RALPH B. GUY, Circuit Judge.

Hockaden and Associates, Inc. (Hockaden or taxpayer) appeals from a United States Tax Court decision, 84 T.C. 13, which determined that it owed substantial excise tax deficiencies. The tax court decision was based upon a finding that unpaid loans made to the taxpayer from an employee profit-sharing plan during the years 1971-1975 resulted in tax liability pursuant to 26 U.S.C. §§ 4975(a) and 4975...

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