Eugenie Denise Mitchell - Page 2

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          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.                                                








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