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RESEARCH CORP. v. COMMISSIONER

Docket No. 9458-10.

138 T.C. 192 (2012)

RESEARCH CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 29, 2012.

Attorney(s) appearing for the Case

John Frederick Daniels, III, for petitioner.

Annie Lee and Peter James Gavagan, for respondent.

OPINION

HAINES, Judge:

Respondent determined a deficiency of $879,468 in petitioner's Federal excise tax for 2003. The issues for decision after concessions are: (1) whether petitioner is liable for excise tax under section 49801 for 2003 on a reversion received from an employee pension plan, and (2) if we find that petitioner is not liable for excise tax under section 4980, whether petitioner is entitled to an overpayment...

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