Schoof v. Commissioner
United States Tax Court
T, an individual, sought approval from the Internal Revenue Service to become a trustee of an individual retirement account (IRA) trust. During 1991, distributions out of individual retirement plans were made to Ps. Those distributions were then rolled over to the IRA trusts of which T was to be the trustee.
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T, an individual, sought approval from the Internal Revenue Service to become a trustee of an individual retirement account (IRA) trust. During 1991, distributions out of individual retirement plans were made to Ps. Those distributions were then rolled over to the IRA trusts of which T was to be the trustee. Concurrently therewith each of the IRA trusts acquired a unit(s) (or fraction thereof) in an investment in a bus stop shelter program. 1. HELD: T is not qualified to serve as a trustee of an IRA trust under sec. 408(a)(2), I.R.C., and sec. 1.408-2(b)(2), Income Tax Regs. 2. HELD, FURTHER,…
1Opinion of the Court
Jacobs, Judge:
Respondent determined deficiencies in petitioners’ 1991 Federal income tax as follows:
Docket No. Petitioner(s) Deficiency
4265-96 Gordon J. and Bonnie L. Schoof $24,605
6210-96 Lyman K. and Judith Kennedy 4,112
6394-96 Melvin L. and Gail H. Rush 8,706
6617-96 Alice M. Johnson1 7,397
6761-96 Robert J. and Bette Barraclough 10,764
7632-96 William N. and Joan E. Hughes 128,225
9362-96 William W. and Joan E. Agnew 46,533
9490-96 Joe O. and Daurine M. Baker 3,002
15341-96 Joseph P. and Genice Spetz 8,724
15342-96 Robert C. and Mary D. Borman 16,462
17606-96 Nurit Haramgaal 11,405
17607-96 John…
2Cases cited6 opinions
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- Taylor v. CommissionerUnited States Tax Court · 1977
- Wood v. CommissionerUnited States Tax Court · 1989
- Rodoni v. CommissionerUnited States Tax Court · 1995
1 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Maloof v. Comm'rUnited States Tax Court · 2005
- Atkin v. Comm'rUnited States Tax Court · 2008
- Bohner v. CommissionerUnited States Tax Court · 2014
- Bobrow v. Comm'rUnited States Tax Court · 2014
- O'Neal v. Comm'rUnited States Tax Court · 2016
31 more not listed; retrieve them via the Exa API.