- 2 - 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE POWELL, Special Trial Judge: By notice of deficiency dated May 25, 1995, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1992 in the amount of $1,348. At the time the petition was filed, petitioners resided in Federal Way, Washington. The issues are (1) whether petitioners are entitled to a deduction for contributions made to Individual Retirement Accounts (IRA's), and (2) whether petitioners are entitled to an overpayment of income taxes paid on separation benefits received from the U.S. Army (Army). Petitioners timely filed a petition with this Court disputing the disallowance of the IRA deduction and claiming an overpayment in the amount of $17,103. The alleged overpayment results from the inclusion of $70,070.60 in income that petitioners contend is exempt from taxation under section 104(a)(4). The facts concerning the $70,070.60 have their genesis in the disintegration of the Soviet Union and the winding down of 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011