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of the distribution of $1,027,229.45 from the Plan, that they
both relied on professional advice when they filed their 1988
income tax return, and that neither of the Halls was aware of the
correct tax consequences flowing from the distribution from Mr.
Hall's pension plan. Accordingly, we perceive no inequity in
holding both Mr. and Mrs. Hall liable for their misapprehension
of the tax laws.
Decision will be entered
for respondent.
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