Ziegler v. Commissioner
United States Tax Court
P, who then practiced law alone, established a qualified retirement plan to which he made contributions on his own behalf. Subsequently, he joined a partnership for the practice of law and received a premature distribution of his interest in such plan.
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P, who then practiced law alone, established a qualified retirement plan to which he made contributions on his own behalf. Subsequently, he joined a partnership for the practice of law and received a premature distribution of his interest in such plan. A new qualified retirement plan was established by the partnership, and contributions were made on behalf of P. Held, under sec. 401(d)(5)(C), I.R.C. 1954, P was prohibited from participating as an owner-employee in a qualified retirement plan for 5 years succeeding the year of the premature distribution, and as a result, he was not entitled to…
1Opinion of the Court
Donald E. Ziegler and Claudia J. Ziegler, Petitioners v. Commissioner of Internal Revenue, Respondent
Ziegler v. Commissioner
Docket No. 10614-75
United States Tax Court
70 T.C. 139; 1978 U.S. Tax Ct. LEXIS 130;
May 2, 1978, Filed
Decision will be entered for the respondent.
P, who then practiced law alone, established a qualified retirement plan to which he made contributions on his own behalf. Subsequently, he joined a partnership for the practice of law and received a premature distribution of his interest in such plan. A new qualified retirement plan was established by the partnership, and…
2Cases cited4 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Southern California Loan Asso. v. CommissionerUnited States Board of Tax Appeals · 1926
- Doing v. CommissionerUnited States Tax Court · 1972
- Ziegler v. CommissionerUnited States Tax Court · 1978