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MEMORANDUM OPINION
LARO, Judge: Gaylord W. Greenlee petitioned the Court to
redetermine respondent's determinations of the following Federal
excise tax deficiencies and additions thereto.
Excise Tax Excise Tax Additions to Tax
Sec. Sec. Sec.
Year 4975(a) 4975(b) 6651(a)(1)1
1985 $1,711 --- $428
1986 2,364 --- 591
1987 3,084 --- 771
1988 3,872 --- 968
1989 4,721 --- 1,180
1990 5,599 $111,839 1,400
1In the notice of deficiency, respondent determined the
additions to tax as follows:
Additions to Tax
Sec.
Year 6651(a)(1)
1985 $ 813
1986 1,123
1987 1,403
1988 1,529
1989 1,581
1990 1,539
Then, in her reply brief, she conceded that the correct additions
to tax are as stated in the text.
The primary issue for decision is whether petitioner engaged
in a prohibited transaction so as to be subject to the first-tier
excise tax under section 4975(a). We hold he did not. Based on
our holding, we also hold that petitioner is not subject to the
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