- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency dated January 27, 1995, respondent determined deficiencies of $190,189 and $45,127 in petitioners’ Federal income tax liabilities for 1989 and 1990, respectively. The only question for decision is whether certain pension plan distributions that petitioner Lawrence L. Kelter received in 1989 and 1990 are includable in gross income. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulation of facts filed by the parties and accompanying exhibits are incorporated herein by this reference. Petitioners resided in Scottsdale, Arizona, at the time the petition in this case was filed. Dr. Kelter Petitioner Lawrence L. Kelter (hereafter, petitioner) is a dentist. In 1987, petitioner began suffering from bilateral carpel tunnel syndrome. Thereafter, in 1987, 1988, and 1989, petitioner underwent several surgeries in order to alleviate his pain and suffering therefrom. The surgeries were unsuccessful in relieving petitioner’s pain. In 1987, petitioner ceased the practice of dentistry.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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