What is IRC 4942?

IRC Section 4942, Taxes on Failure to Distribute Income – Carryover of Excess Distributions or Undistributed Income

What is the history of the 4942 excise tax?

In H. Fort Flowers Foundation, Inc. v. Commissioner, 72 T.C. 399 (T.C. 1979), the Tax Court rejected the taxpayer’s classification of a transaction which occurred in a closed year, thereby allowing imposition of the Section 4942 excise tax in open years.

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