Gordon J. and Bonnie L. Schoof - Page 2

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               the IRA trusts of which T was to be the trustee.                       
               Concurrently therewith each of the IRA trusts acquired a               
               unit(s) (or fraction thereof) in an investment in a bus                
               stop shelter program.                                                  
                    1. Held:  T is not qualified to serve as a trustee                
               of an IRA trust under sec. 408(a)(2), I.R.C., and sec.                 
               1.408-2(b)(2), Income Tax Regs.                                        
                    2. Held, further, the distributions to Ps were                    
               taxable in the year of distribution and were subject to                
               the 10-percent additional tax pursuant to sec. 72(t),                  
               I.R.C.                                                                 
                    3. Held, further, under Wood v. Commissioner, 93                  
               T.C. 114 (1989), Ps did not substantially comply with the              
               rollover contribution requirements of sec. 408(d),                     
               I.R.C., so as to exclude the distributions from income.                


               Stephen M. Goodman, for petitioners.                                   
               Lisa W. Kuo, for respondent.                                           


               JACOBS, Judge:    Respondent  determined  deficiencies  in             
          petitioners' 1991 Federal income tax as follows:                            
          Docket                                                                      
          No.            Petitioner(s)                      Deficiency                
          4265-96   Gordon J. and Bonnie L. Schoof          $24,605                   
          6210-96   Lyman K. and Judith Kennedy             4,112                     
          6394-96   Melvin L. and Gail H. Rush              8,706                     
          6617-96   Alice M. Johnson1                       7,397                     
          6761-96   Robert J. and Bette Barraclough         10,764                    
          7632-96   William N. and Joan E. Hughes           128,225                   
          9362-96   William W. and Joan E. Agnew            46,533                    





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