- 3 -
9490-96 Joe O. and Daurine M. Baker 3,002
15341-96 Joseph P. and Genice Spetz 8,724
15342-96 Robert C. and Mary D. Borman 16,462
17606-96 Nurit Haramgaal 11,405
17607-96 John S. Husmann and Elinor C. MacKinnon 4,606
1 A notice of deficiency was issued to Alice M. Johnson and her
husband Duaine E. Johnson. Mr. Johnson died on Sept. 1, 1994. An
estate was not opened for him. Alice M. Johnson, as surviving
spouse, is the sole petitioner in docket No. 6617-96.
Each of these 12 consolidated cases involves the following
transactions: (a) A distribution from an individual retirement
plan, (b) an attempted tax-free rollover contribution of that
distribution to a newly established putative individual retirement
account trust, and (c) a purchase of a unit(s) (or fraction
thereof) in a bus stop shelter program. The issue for decision is
whether the rollover qualifies for tax-free treatment. Resolution
of this issue depends in part upon whether the trustee of the
putative individual retirement account trust is an eligible
trustee.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated herein
by this reference.
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