Clark v. Comm'r
United States Tax Court
T was a participant in her employer's defined benefit pension plan, which was tax qualified under sec. 401, I.R.C. In 1988, when she was 54 years old, the plan was terminated, and her total accrued benefit in the plan was distributed to her.
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T was a participant in her employer's defined benefit pension plan, which was tax qualified under sec. 401, I.R.C. In 1988, when she was 54 years old, the plan was terminated, and her total accrued benefit in the plan was distributed to her. The distribution was made to T solely on account of the plan's termination and not "on account of separation from service or disability." 1. Held: The distribution did not qualify as a "lump sum distribution" (a term of art defined in sec. 402(e)(4)(A), I.R.C.) since it was not made on account of any of the four alternative events specified in sec.…
1Opinion of the Court
Katherine L. Clark, Petitioner v. Commissioner of Internal Revenue, Respondent
Clark v. Comm'r
Docket No. 7588-92
United States Tax Court
101 T.C. 215; 1993 U.S. Tax Ct. LEXIS 55; 101 T.C. No. 15; 17 Employee Benefits Cas. (BNA) 1363;
September 14, 1993, Filed
Decision will be entered for respondent.
T was a participant in her employer's defined benefit pension plan, which was tax qualified under sec. 401, I.R.C. In 1988, when she was 54 years old, the plan was terminated, and her total accrued benefit in the plan was distributed to her. The distribution was made to T solely on account of the plan's…
2Cases cited8 opinions
- Foxman v. CommissionerUnited States Tax Court · 1964
- Bolton v. CommissionerUnited States Tax Court · 1981
- Dorance D. And Helen A. Bolton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1986
- De Marco v. CommissionerUnited States Tax Court · 1986
3 more not listed; retrieve them via the Exa API.