Carter v. Commissioner of Internal Revenue

Tax Court did not err in finding that plaintiffs were collaterally estopped from proceeding on their claim that change in their defined pension plan, which precluded them from obtaining immediate distribution of benefits violated ERISA, Internal Revenue Code, and/or contractual anti-cutback provisions of said plan. Record showed that plaintiffs had participated in prior action, where Ct. of Appeals had ultimately concluded that immediate payment of pension benefits that plaintiffs sought while still working for defendant was not right protected by ERISA because subject plan had not been terminated. Moreover, in order for plaintiff to prevail in instant action, they must first establish that defendant had terminated subject plan, which would directly contradict holding in prior case.