§156

- 34 - We hold that petitioners did not contribute the house or an undivided interest in the Vienna property to the FCFRD.

in a Personal Residence A remainder is a future interest in property “limited in favor of a transferee in such manner that it can become a present interest upon the expiration of all prior interests simultaneously created”. 2 Restatement, Property, sec. 156 (1936). A vested remainder ripens into title in fee upon the death of the life tenant. See, e.g., Miller v. Citizens Nat’l Bank, 60 S.E.2d 868, 870 (Va. 1950). When a taxpayer grants a fire department a license to conduct training exercises

156 (“authority from time to time to make, amend, and rescind * * * such rules and regulations as may be necessary”)]; Sullivan v. Everhart, 494 U.S. 83 (1990)[issued under 42 U.S.C.(a) 401 et seq. (Secretary authorized to “make rules and regulations and to establish procedures not inconsistent with this subchapter, which are necessary”)]; Mas

156 ((“authority from time to time to make, amend, and rescind * * * such rules and regulations as may be necessary”)); Sullivan v. Everhart, 494 U.S. 83 (1990) (issued under 42 U.S.C. secs. 401 et seq. ((Secretary authorized to “make rules and regulations and to establish procedures not inconsistent with this subchapter, which are necessary’)

the ultimate outcome of an investment is not proof that the investment failed to meet the prudent investor rule. See DeBruyne v. Equitable Life Assur. Socy. of U.S., 920 F.2d 457, 465 (7th Cir. 1990); see also Norton Bankruptcy Law and Practice 2d, sec. 156:9 (1997-98). By examining the totality of transgressions that Morrissey committed, we can assess whether it was an abuse of discretion for respondent to disqualify the Defined Benefit Plan. Morrissey, as sole shareholder of petitioner--the p

hus, the ultimate outcome of an investment is not proof that the investment failed to meet the prudent investor rule. DeBruyne v. Equitable Life Assur. Socy. of U.S., 920 F.2d 457, 465 (7th Cir. 1990); see also Norton Bankruptcy Law and Practice 2d, sec. 156:9 (1997-98). - 33 - Accordingly, in determining whether a plan has satisfied the exclusive benefit rule, we must consider the risk of the loan to the plan when the loan was made, taking into account its relative safety, its effect on the div

for the trust property and who did not participate to any degree in the dispositive provisions of the trust. The same distinction applies to Security-First Natl. Bank v. Wright, supra, and the hypothetical situation discussed in IIA Scott, Trusts, sec. 156.3 (4th ed. 1987). Petitioners also cite Lehman v. Commissioner, 109 F.2d 99 (2d Cir. 1940), affg. 39 B.T.A. 17 (1939), for the proposition that a person is a settlor of a trust if he furnishes consideration for the trust. Lehman involved reci