T.C. Memo. 2004-156
UNITED STATES TAX COURT
JERRY L. HILL AND VALERIE J. HILL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7058-03. Filed June 30, 2004.
Joe Alfred Izen, Jr., for petitioners.
Huong Duong, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine a $130,260 deficiency in their 1999 Federal income
tax and a $26,052 accuracy-related penalty under section 6662(a).
Following concessions, including petitioners’ concession that the
trust at hand (Re-Cap Trust) is disregarded for Federal income
tax purposes, we decide whether petitioners may deduct certain
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