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Paying for Sins of the Master: An Analysis of the Tax Effects of Pension Plan Disqualification and a Proposal for Reform

Abstract

This Article describes the tax effects that occur when the Internal Revenue Service disqualifies a pension or profit sharing plan, and suggests that disqualification is an inappropriate sanction both from a retirement policy and tax administration standpoint. Professor Colombo proposes replacing disqualification in its current form with an excise tax sanction system, supplemented by a much narrower form of disqualification in certain cases.

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34 Ariz. L. Rev. 53 (1992)

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