- 2 - payment of these plan expenses. See sec. 1.404(a)- 3(d), Income Tax Regs. Held, further, accuracy-related penalty under sec. 6662(a) sustained. Leonard Bailin, for petitioner. Rose E. Gole, for respondent. OPINION LARO, Judge: The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of a deficiency in tax for 1993 of $118,964, and an accuracy-related penalty for negligence under section 6662(a) of $23,793. After concessions of the parties, we decide the following issues: 1. Whether petitioner may deduct legal fees of $97,274 paid on behalf of its qualified pension plan and certain individuals. We hold it may to the extent discussed herein. 2. Whether petitioner is liable for the accuracy-related penalty for negligence under section 6662(a). We hold it is. Unless otherwise noted, section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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