Michael G. Bunney - Page 2

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               Lawrence J. Kaplan, for petitioner.                                    
               Christine V. Olsen, for respondent.                                    


               LARO, Judge:  This case is before the Court fully                      
          stipulated.  See Rule 122.  Petitioner petitioned the Court to              
          redetermine respondent’s determination of an $84,080 deficiency             
          in Federal income tax for 1993 and a $16,816 accuracy-related               
          penalty for negligence under section 6662(a).                               
               After concessions,1 we must decide the following issues with           
          respect to 1993:                                                            
               1.  Whether petitioner’s gross income includes the entire              
          $125,000 in distributions he received from his individual                   
          retirement accounts (IRA’s).  We hold it does.                              

               1Petitioner concedes the following: (1) His gross income               
          includes a $64,054 gain on the sale of his home; (2) he may                 
          deduct only $1,476 of the $11,735 claimed for legal and                     
          professional fees paid; (3) he may not deduct the $11,000 claimed           
          with respect to the purchase of a horse, but may take a Schedule            
          F, Profit or Loss From Farming, depreciation deduction in the               
          amount of $393; and (4) he may not deduct the $5,178 claimed for            
          repair expenses paid.  Petitioner also concedes that he should be           
          taxed on one-half of the $125,000 in IRA distributions he                   
          received in 1993, but he challenges whether he is liable for tax            
          on the other half.                                                          

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