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Akhilesh S. and Dipti A. Desai, docket No. 2981-97
Addition to Tax Accuracy-Related Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $42,047 — $8,409
1992 15,751 — 3,150
1993 25,016 — 5,003
Kevin T. and Cheryl McManus, docket No. 2985-97
Addition to Tax Accuracy-Related Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $6,821 — $1,364
1992 6,146 — 1,229
1993 8,214 — 1,643
Arthur and Lois M. Hirshkowitz, docket No. 2994-97
Addition to Tax Accuracy-Related Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $82,933 — $16,587
1992 45,233 — 9,047
1993 79,853 — 15,971
Marlton Group
Wan B. and Cecilia T. Lo, docket No. 4572-97
Addition to Tax Accuracy-Related Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1993 $41,807 — $8,361
1994 49,970 — 9,994
We decide the following issues:
1. Whether Neonatology and Lakewood may deduct
contributions to their respective plans in excess of the amounts
needed to purchase current-year (term) life insurance for their
covered employees. We hold they may not.
2. Whether Lakewood may deduct payments made outside of its
plan to purchase additional life insurance for two of its
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