T.C. Memo. 2001-34
UNITED STATES TAX COURT
ANDREW P. AND ROSEANNE L. GALLAGHER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 659-00. Filed February 13, 2001.
Andrew P. and Roseanne L. Gallagher, pro se.
Thomas L. Fenner, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $2,280
in petitioners’ Federal income tax for 1997. The issues for
decision are whether the distribution to Andrew P. Gallagher
(petitioner) from an individual retirement account (IRA) was
includable in petitioners’ gross income and whether that same
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