111 T.C. No. 20
UNITED STATES TAX COURT
DONA ELIZABETH CONWAY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22257-96. Filed December 30, 1998.
Held: Under the facts of this case, direct
transfer of a portion of funds invested in an annuity
contract into another annuity contract qualifies as a
nontaxable exchange under sec. 1035, I.R.C. Other
issues also decided.
Dona Elizabeth Conway, pro se.
Blaine C. Holiday, for respondent.
SWIFT, Judge: Respondent determined a deficiency of
$123,855 and an addition to tax and a penalty with respect to
petitioner's Federal income tax for 1994.
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