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LEIB v. COMMISSIONER

Docket No. 10688-85.

88 T.C. 1474 (1987)

ALDEN M. LEIB, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 16, 1987.

Attorney(s) appearing for the Case

Joseph F. Dillon, R. Peter Prokop, George J. Haddad, and Robert E. Forrest, for the petitioner.

Roberta M. Hamm, for the respondent.

GOFFE, Judge:

The Commissioner determined that petitioner was liable for the excise tax imposed by section 4975(a)1 in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qualify as a prudent investment if judged under the highest fiduciary standards; (2) whether petitioner is liable...

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