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WOOD v. C.I.R.

No. 91-1717.

955 F.2d 908 (1992)

Dallas C. WOOD, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided January 31, 1992.

Attorney(s) appearing for the Case

Kenneth L. Greene, Tax Div., U.S. Dept. of Justice, Washington, D.C., argued (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Steven W. Parks, Tax Div., U.S. Dept. of Justice, on brief), for respondent-appellant.

Robert Gerald Nath, Odin, Feldman & Pittleman, P.C., Fairfax, Va., argued, for petitioner-appellee.

Before WIDENER and NIEMEYER, Circuit Judges, and MERHIGE, Senior District Judge for the Eastern District of Virginia, sitting by designation.

OPINION

NIEMEYER, Circuit Judge:

Section 4975 of the Internal Revenue Code imposes an excise tax on any "disqualified person" who participates in a "prohibited transaction" with a qualified defined benefit plan created under ERISA. We are presented with the question of whether the assignment of third-party promissory notes by a disqualified person to a plan in discharge of a funding obligation is a prohibited transaction. The Tax Court determined that it...

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