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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.
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