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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax of $5,181 for the taxable year 1998.
The issues for decision are:
(1) Whether petitioners are entitled to deduct Washington
State real estate excise taxes of $12,209. We hold that they are
not.
(2) Whether petitioners are liable under section 72(t) for
the 10-percent additional tax on an early distribution from
petitioner Kurt Steven Urban’s (Mr. Urban) individual retirement
account (IRA). We hold that they are to the extent provided
herein.
An adjustment to the amount of petitioners’ itemized
deductions is a purely computational matter, the resolution of
which is dependent on our disposition of the first disputed
issue.
Background
At the time that the petition was filed, petitioners
resided in Portland, Oregon.
A. Real Estate Excise Tax
From 1994 through 1998, petitioners owned and resided in a
single-family home located at 5518 174th Place Southeast,
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