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Mark L. Hulse and Laurence D. Ziegler, for respondent.
OPINION
TANNENWALD, Judge: Respondent determined a deficiency in
petitioner's Federal income tax in the amount of $170,968 and an
accuracy-related penalty under section 6662(a)1 in the amount of
$34,194 for the taxable year 1993. The issues for decision are:
(1) Whether petitioner's use of distributions from Keogh and
individual retirement accounts (IRA's) to purchase stock which
was contributed to an IRA constitutes a tax-free rollover
contribution;
(2) whether petitioner received a taxable distribution of
money not contributed to an IRA; and
(3) whether petitioner is liable for the accuracy-related
penalty under section 6662(a).
This case was submitted fully stipulated under Rule 122.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Flushing, New York, at the time he filed the petition in this
case. During 1993, petitioner was a self-employed accountant.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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