United States Tax Court May 28, 1996, 791-94, 792-94 (Alfred E. Gallade v. Commissioner)

106 T.C. No. 20

UNITED STATES TAX COURT

ALFRED E. GALLADE, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket Nos. 791-94, 792-94. Filed May 28, 1996.

C, P’s wholly owned corporation, operated a

pension plan in which P participated. Because of C’s

poor financial disposition, P executed a “waiver”, to

assign his fully vested, accrued benefits to C.