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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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