- 2 -
Year Deficiency Sec. 6662 Penalty
1990 $22,763 $4,553
1991 25,581 5,116
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue.
The issues remaining for decision are: (1) Whether
loans that petitioner received from a qualified employer
plan during 1986, together with accrued interest, are
properly treated under section 72(p) as distributions from
the plan in 1991, as respondent contends, or in a prior
year that is not before the Court, as petitioners contend;
(2) in the case of loans from a qualified employer plan
that are treated as distributions under section 72(p),
whether subsequent accruals of interest are properly
treated as additional distributions from the plan; and (3)
whether petitioners are liable for the accuracy-related
penalty for negligence prescribed by section 6662.
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts, supplemental stipulation
of facts, and exhibits attached to each are incorporated
herein by this reference. Petitioners are husband and wife
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011