- 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011