Gaylord W. Greenlee - Page 1

                                 T.C. Memo. 1996-378                                  

                               UNITED STATES TAX COURT                                

                         GAYLORD W. GREENLEE, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16615-94.                  Filed August 15, 1996.           

                    P was the sole participant and plan administrator                 
               of a pension plan for corporation A and owned 18                       
               percent of an unrelated corporation, C.  In 1982, P                    
               requested the plan's independent trustee to consider                   
               lending trust funds to C.  The trustee had full                        
               investment discretion under the plan's trust document                  
               and authorized the loan.                                               
                    Held:  P is not subject to the 5-percent excise                   
               tax of sec. 4975(a), I.R.C., because he did not engage                 
               in a prohibited transaction under sec. 4975(c)(1)(E),                  

               Gaylord W. Greenlee, pro se.                                           
               Julia L. Wahl, for respondent.                                         

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