Benbow v. Commissioner
United States Tax Court
Petitioner-husbands received distributions in 1978 from a trust which was part of a pension plan. They "rolled over" these distributions into individual retirement accounts. In 1980, respondent revoked the favorable determination letter that had previously been issued to the plan.
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Petitioner-husbands received distributions in 1978 from a trust which was part of a pension plan. They "rolled over" these distributions into individual retirement accounts. In 1980, respondent revoked the favorable determination letter that had previously been issued to the plan. This revocation was made retroactive to Jan. 1, 1976. Held: 1. To the extent that any distribution is attributable to periods before Jan. 1, 1976, the amount thereof is treated as a distribution which, under sec. 402(a)(5), I.R.C. 1954, has been rolled over tax free. The post-1975 portion of each such distribution…
1Opinion of the Court
Donald L. Benbow and Patricia J. Benbow, Daniel W. Cass, Jr., and Barbara Cass, Earl R. Lueckel and Lois B. Lueckel, Frederic E. Saunders and Mary Alice Saunders, and William H. Strong and Ella K. Strong, Petitioners v. Commissioner of Internal Revenue, Respondent
Benbow v. Commissioner
Docket No. 23410-82
United States Tax Court
82 T.C. 941; 1984 U.S. Tax Ct. LEXIS 58; 82 T.C. No. 71; 5 Employee Benefits Cas. (BNA) 1714;
June 7, 1984, Filed
Decision will be entered under Rule 155.
Petitioner-husbands received distributions in 1978 from a trust which was part of a pension plan. They "rolled over"…
2Cases cited18 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- United States v. Ophelia Johnson and Ophelia R. Johnson, as Under the Last Will and Testament of Clifford L. Johnson, DeceasedCourt of Appeals for the Fifth Circuit · 1964
- Metzger Trust v. CommissionerUnited States Tax Court · 1981
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