Thiessen v. Comm'r
United States Tax Court
In June 2003 Ps rolled over their tax-deferred retirement funds into newly formed individual retirement accounts (IRAs), caused the IRAs to acquire the initial stock of a newly formed C corporation (E), and caused E to acquire the assets of an existing business. Ps guaranteed the repayment of a loan that E received from the seller of the assets as part of the acquisition price.
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In June 2003 Ps rolled over their tax-deferred retirement funds into newly formed individual retirement accounts (IRAs), caused the IRAs to acquire the initial stock of a newly formed C corporation (E), and caused E to acquire the assets of an existing business. Ps guaranteed the repayment of a loan that E received from the seller of the assets as part of the acquisition price. Ps' 2003 joint Federal income tax return reported that the rollover of the retirement funds into the IRAs was nontaxable. The return did not reveal that Ps had guaranteed the loan. R determined that Ps failed to report…
1Opinion of the Court
JAMES E. THIESSEN AND JUDITH T. THIESSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Thiessen v. Comm'r
Docket No. 11965-10
United States Tax Court
146 T.C. 100; 2016 U.S. Tax Ct. LEXIS 8; 146 T.C. No. 7;
March 29, 2016, Decided
Decision will be entered for respondent.
In June 2003 Ps rolled over their tax-deferred retirement funds into newly formed individual retirement accounts (IRAs), caused the IRAs to acquire the initial stock of a newly formed C corporation (E), and caused E to acquire the assets of an existing business. Ps guaranteed the repayment of a loan that E received…
2Cases cited25 opinions
- Marbury v. MadisonSupreme Court of the United States · 1803
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