Calfee, Halter, & Griswold v. Commissioner
United States Tax Court
Ps are employers who each established pension or profit-sharing plans. Each plan contains a provision which permits Ps' contributions to their respective plans to be returned to them under certain circumstances. The language of each such provision tracks that of sec. 403(c)(2) of title I of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, 88 Stat. 829, and is not broader than the statutory language.
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Ps are employers who each established pension or profit-sharing plans. Each plan contains a provision which permits Ps' contributions to their respective plans to be returned to them under certain circumstances. The language of each such provision tracks that of sec. 403(c)(2) of title I of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, 88 Stat. 829, and is not broader than the statutory language. The fiduciary standards of ERISA sec. 403(c) were not enacted as part of the Internal Revenue Code of 1954; however, Congress drafted title I and title II of ERISA in…
1Opinion of the Court
Calfee, Halter & Griswold, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Calfee, Halter, & Griswold v. Commissioner
Docket Nos. 43655-85R, 43656-85R, 43657-85R, 43658-85R, 43659-85R, 2753-86R, 2754-86R, 2755-86R, 2756-86R
United States Tax Court
88 T.C. 641; 1987 U.S. Tax Ct. LEXIS 38; 88 T.C. No. 35; 8 Employee Benefits Cas. (BNA) 1329;
March 23, 1987. March 23, 1987, Filed
Decisions will be entered for the petitioners.
Ps are employers who each established pension or profit-sharing plans. Each plan contains a provision which permits Ps' contributions to their respective…
2Cases cited2 opinions
- Wallace v. United StatesDistrict Court, E.D. Arkansas · 1968
- Calfee, Halter, & Griswold v. CommissionerUnited States Tax Court · 1987