Wood v. Commissioner
United States Tax Court
P received a lump-sum distribution of cash and stock from a profit-sharing plan. In furtherance of his plan to avoid tax on the distribution, P established an IRA with a large brokerage company as trustee. P delivered the cash and stock to the trustee with instructions that all of the cash and stock be held in the IRA.
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P received a lump-sum distribution of cash and stock from a profit-sharing plan. In furtherance of his plan to avoid tax on the distribution, P established an IRA with a large brokerage company as trustee. P delivered the cash and stock to the trustee with instructions that all of the cash and stock be held in the IRA. The records of the trustee properly reflected the transfer of the cash to the IRA within the 60-day period required by sec. 402(a)(5)(C), I.R.C. 1954, but mistakenly recorded the stock as having been transferred to another of P's accounts. Approximately 4 months after the…
1Opinion of the Court
William Wood and Lois Wood, Petitioners v. Commissioner of Internal Revenue, Respondent
Wood v. Commissioner
Docket No. 20039-87
United States Tax Court
93 T.C. 114; 1989 U.S. Tax Ct. LEXIS 110; 93 T.C. No. 12; 11 Employee Benefits Cas. (BNA) 1401;
July 31, 1989July 31, 1989, Filed
An appropriate order will be issued and decision will be entered under Rule 155.
P received a lump-sum distribution of cash and stock from a profit-sharing plan. In furtherance of his plan to avoid tax on the distribution, P established an IRA with a large brokerage company as trustee. P delivered the cash and stock to…
2Cases cited9 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Dean v. CommissionerUnited States Tax Court · 1971
- Wood v. CommissionerUnited States Tax Court · 1989
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