- 2 - 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 46,533Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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