Legal Opinion
Baetens v. Commissioner
Court of Appeals for the Sixth Circuit
Decided December 4, 1985No. Nos. 84-1471, 84-1830PublishedCited by 12 opinions
1Opinion of the Court
BOYCE F. MARTIN, JR., Circuit Judge.
The Commissioner of Internal Revenue has appealed the tax court’s application of section 402(a)(5) of the Internal Revenue Code of 1954, 26 U.S.C. § 402(a)(5), in each of these cases. Section 402(a)(5) provides that employees may receive distributions from qualified trusts related to qualified profit-sharing plans1 and may reinvest the distributions in certain Individual Retirement Accounts without being taxed on the distributions in the interim.2 In these cases on appeal, the once qualified plan and trust were no longer qualified at the time of…
2Cases cited14 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
9 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Fazi v. CommissionerUnited States Tax Court · 1994
- Armco, Inc. v. CommissionerUnited States Tax Court · 1987
- Henry T. Boggs and Jeanne Boggs v. Commissioner of Internal Revenue, Henry T. Boggs and Jeanne Boggs v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1986
- Theodore L. Baetens and Joyce R. Baetens v. Commissioner of Internal Revenue, Donald L. Benbow Patricia J. Benbow Daniel W. Cass, Jr. Barbara Cass Earl R. Lueckel Lois E. Lueckel Frederic E. Saunders Mary Alice Saunders William H. Strong and Ella K. Strong v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- Armco, Inc. v. CommissionerUnited States Tax Court · 1987
7 more not listed; retrieve them via the Exa API.