- 17 -
annuities were not qualified plans, and petitioners have never
contended that their plans were qualified plans. Moreover,
equitable estoppel can be applied against the Government only
when the following elements, at a minimum, are present: (1) A
false representation or wrongful, misleading silence by the party
against whom the opposing party seeks to invoke the doctrine; (2)
an error in a statement of fact and not in an opinion or
statement of law; (3) ignorance of the true facts; (4) reasonable
reliance on the acts or statements of the one against whom
estoppel is claimed; and (5) adverse effects of the acts or
statement of the one against whom estoppel is claimed. Norfolk
S. Corp. v. Commissioner, 104 T.C. 13, 60 (1995), modified 104
T.C. 417 (1995), affd. 140 F.3d 240 (4th Cir. 1998). The
doctrine is applied against the Government with the utmost
14(...continued)
Special rules apply to partial rollovers of property.
For more details on rollovers, including distributions under
qualified domestic relations orders, see Pub. 575.
Lump-Sum Distributions
If you received a lump-sum distribution from a profit-
sharing or retirement plan, your Form 1099-R should have the
"Total distribution" box in box 2b checked. You may owe an
additional tax if you received an early distribution from a
qualified retirement plan and the total amount was not
rolled over. For details, see the instructions for line 53
that begin on page 36.
Enter the total distribution on line 16a and the
taxable part on line 16b.
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