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on the committee.
Neither petitioner nor the Garrahan Agency filed a Form
5330, Return of Excise Tax Related to Employee Benefit Plans, for
any of the years at issue.
F. Notices of Deficiency
Respondent issued notices of deficiency determining that
petitioners are liable for excise tax deficiencies under section
4975(a) and (b) and additions to tax under section 6651(a)(1) for
1982 through 1993. Respondent determined that petitioners were
"disqualified persons" and that they had participated in
prohibited transactions under section 4975(c).
II. OPINION
A. Excise Tax on Prohibited Transactions
Section 4975(a) imposes an excise tax on prohibited
transactions between retirement plans and disqualified persons.
Section 4975(a) imposes a 5-percent tax on the amount involved,
as defined by section 4975(f)(4), for each prohibited
transaction. Any disqualified person who participates in a
prohibited transaction is liable for the tax. Sec. 4975(a). A
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