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FAZI v. COMMISSIONER

Docket No. 13139-91.

102 T.C. 695 (1994)

JOHN U. FAZI AND SYLVIA FAZI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 19, 1994.

Attorney(s) appearing for the Case

Paul A. Kasicky, James E. Abraham, and Robert V. Campedel (specially recognized), for petitioners.

Julia L. Wahl, for respondent.

GERBER, Judge:

Respondent determined a $434,582 deficiency in petitioners' 1987 Federal income tax. The deficiency is attributable to distributions petitioners received from a pension plan. The issues for our consideration are: (1) Whether the pension plan and related trust were unqualified at the time of the distributions to petitioners;1 and (2) if the plan and trust were unqualified, whether attempted rollovers to individual...

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