Anthony J. and Denise D. Sadberry - Page 17

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          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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