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second-tier excise tax under section 4975(b) and the additions to
tax under section 6651(a)(1). Unless otherwise indicated,
section references are to the Internal Revenue Code applicable to
the years in issue. Rule references are to the Tax Court Rules
of Practice and Procedure.
Background
This case has been submitted fully stipulated under
Rule 122. The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Petitioner resided in
Prospect, Pennsylvania, when he filed his petition.
Petitioner is the sole participant and the plan
administrator of the Gaylord W. Greenlee, P.C., Profit Sharing
Plan and Trust (Plan).1 Article X of the Plan document sets
forth the following responsibilities for the plan administrator:
The Plan Administrator shall, as named fiduciary,
have exclusive authority to control and manage the
operation and administration of the Plan. The Plan
Administrator shall perform all general administration
duties under the Plan, including (but not limited to)
the following:
(a) To determine all questions relating to the
eligibility of Employees to participate or to continue
participation;
(b) To compute, certify and direct the Trustee
with respect to the amount and kind of benefits to
which any Participant or Beneficiary is entitled;
1 Petitioner is, and at all relevant times was, a lawyer
duly licensed to practice in Pennsylvania.
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Last modified: May 25, 2011