- 10 - 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). APage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011