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JANPOL v. COMMISSIONER

Docket Nos. 5586-92, 5587-92.

102 T.C. 499 (1994)

ARTHUR S. JANPOL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT DONALD BERLIN, PETITIONER v. COMMISSIONER INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 28, 1994.

Attorney(s) appearing for the Case

John N. Lieuwen and Patricia Tucker, for petitioners.

Thomas F. Eagan, for respondent.

SUPPLEMENTAL OPINION

COHEN, Judge:

In Janpol v. Commissioner, 101 T.C. 518 (1993), we held that petitioners were liable for section 4975(a) excise taxes on prohibited transactions. We incorporate and rely on the findings of fact set forth in that opinion. Briefly, we held that petitioners' loans to the Imported Motors Profit Sharing Trust (the trust) were prohibited transactions giving rise to excise tax liability...

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