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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.
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