Ancira v. Comm'r
United States Tax Court
P had a self-directed IRA account of which C was the custodian. P requested that C purchase common stock in X for the IRA. Although the investment in X stock was not prohibited, C, as a matter of policy, refused to purchase the stock because X was not publicly traded. P arranged for C to issue a check drawn on the IRA account made payable to X. C sent the check to P, who forwarded it to X. X issued the stock in the name of P's IRA.
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P had a self-directed IRA account of which C was the custodian. P requested that C purchase common stock in X for the IRA. Although the investment in X stock was not prohibited, C, as a matter of policy, refused to purchase the stock because X was not publicly traded. P arranged for C to issue a check drawn on the IRA account made payable to X. C sent the check to P, who forwarded it to X. X issued the stock in the name of P's IRA. P received X's stock and delivered the stock to C. R determined that there was a distribution from the IRA to P. Held: P was a conduit for C, and there was no…
1Opinion of the Court
ROBERT ANCIRA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ancira v. Comm'r
No. 425-01
United States Tax Court
119 T.C. 135; 2002 U.S. Tax Ct. LEXIS 43; 119 T.C. No. 6;
September 24, 2002, Filed
Decision will be entered for taxpayer.
P had a self-directed IRA account of which C was the custodian.
P requested that C purchase common stock in X for the IRA.
Although the investment in X stock was not prohibited, C, as a
matter of policy, refused to purchase the stock because X was
not publicly traded. P arranged for C to issue a check drawn on
the IRA account made payable to X. C sent the…
2Cases cited8 opinions
- Diamond v. CommissionerUnited States Tax Court · 1971
- Sol Diamond and Muriel Diamond v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1974
- Darby v. CommissionerUnited States Tax Court · 1991
- BUNNEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- Wood v. CommissionerUnited States Tax Court · 1989
3 more not listed; retrieve them via the Exa API.