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),
I.R.C.
Gaylord W. Greenlee, pro se.
Julia L. Wahl, for respondent.
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