Hellweg v. Comm'r
United States Tax Court
Ps held ownership interests in and controlled an S corporation. Ps' Roth IRAs formed a DISC which entered into a commission agreement with the S corporation. For excise tax purposes only, R recharacterized commission payments from the S corporation to the DISC as distributions to Ps followed by Ps' contribution of the proceeds to their Roth IRAs.
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Ps held ownership interests in and controlled an S corporation. Ps' Roth IRAs formed a DISC which entered into a commission agreement with the S corporation. For excise tax purposes only, R recharacterized commission payments from the S corporation to the DISC as distributions to Ps followed by Ps' contribution of the proceeds to their Roth IRAs. R determined that Ps were each liable for: (1) Excise taxes on excess contributions to their Roth IRAs under sec. 4973, I.R.C.; (2) an accuracy-related penalty under sec. 6662(a), I.R.C.; and (3) additions to tax under sec. 6651(a)(1), I.R.C., for…
1Opinion of the Court
ERIN N. HELLWEG, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hellweg v. Comm'r
Docket Nos. 14502-08, 14523-08, 14525-08, 14527-08.
United States Tax Court
T.C. Memo 2011-58; 2011 Tax Ct. Memo LEXIS 54; 101 T.C.M. (CCH) 1261;
March 9, 2011, Filed
Appropriate orders and decisions will be entered granting petitioners' Motion for Summary Judgment.
Ps held ownership interests in and controlled an S corporation. Ps' Roth IRAs formed a DISC which entered into a commission agreement with the S corporation. For excise tax purposes only, R recharacterized commission payments from the…
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- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
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