T.C. Memo. 1999-80
UNITED STATES TAX COURT
EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC.,
Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1616-97. Filed March 16, 1999.
Paul F. Markham, for petitioners.
Mark L. Hulse and Gary W. Bornholdt, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioners are
liable for deficiencies in the excise tax imposed on prohibited
transactions between retirement plans and disqualified persons by
section 4975(a) and (b) and additions to tax as follows:
Deficiencies Additions to tax
Sec. Sec. Sec. Sec.
Year 4975(a) 4975(b) 6651(a)(1) 6651(a)(2)
1982 $14,693 -0- $3,306 $3,673
1983 16,777 -0- 3,775 4,194
1984 30,969 -0- 6,968 7,742
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