- 12 - Woodward v. Commissioner, 397 U.S. 572 (1970); United States v. Hilton Hotels Corp., 397 U.S. 580 (1970). Accordingly, the organizational expenses of Worldly Connections, Inc., paid by petitioner are not deductible on petitioner’s 1994 Federal income tax return. Similarly, to the extent that petitioner paid any additional expenses for Worldly Connections, Inc., during the 1994 taxable year out of her own pocket (e.g., $155), these expenses should also be considered contributions of capital and are nondeductible to petitioner on her individual Federal income tax return. See Deputy v. du Pont, supra. II. Section 72(t) Tax Section 72(t) imposes an additional 10-percent tax on the amount of an early distribution from a qualified retirement account (as defined in section 4974(c)). See sec. 72(t). Section 72(t)(2) provides for certain exceptions to the imposition of this 10-percent tax. Petitioner received a $35,000 distribution in 1993 and a $8,717.32 distribution in 1994 from her IRA’s, which are qualified retirement plans under section 4974(c)(4). Petitioner testified that she withdrew the money from her IRA’s to provide for her own subsistence and that of her family. This is not one of the exceptions set forth in section 72(t)(2), and petitioner has failed to present evidence that would trigger any of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011