Quiller Barnes v. Commissioner of Internal Revenue

Were the Petitioner’s 1996 Pension funds from Pacific Bell Telephone Company, which was properly rolled over within 60 days of his retirement, per his employer’s regulations and the Internal Revenue regulations 402 (c) and 408(d)(3) taxable income? Because of the unusual circumstances regarding this tax situation, the Petitioner’s pension fund was mistakenly taxed; therefore, should the statute of limitation regarding this tax situation be waived? And the Respondent obligated to return to the Petitioner any taxes, interest and penalties Petitioner paid for the pretax and taxation of the Petitioner’s untaxable Pension Funds.