- 2 - all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioner resided in Sacramento, California. From 1984 to 2001, petitioner was employed as an attorney with various section 501(c)(3) organizations, which organizations made contributions on petitioner’s behalf to four separate section 403(b) tax-deferred annuity accounts and to one tax- deferred simplified employee plan/individual retirement account (SEP-IRA). The employer contributions made to petitioner’s annuity and SEP-IRA accounts were made with funds which were not included in petitioner’s taxable income. On February 28, 2001, petitioner’s then-current employer went out of business, and petitioner was laid off. As a result of being laid off, in the spring of 2001 petitioner applied for and received unemployment benefits from the State of California. In June of 2001, petitioner began practicing law as a partner in her own law partnership, which partnership struggled financially throughout 2001.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011