Legal Opinion

Swanson v. Comm'r

United States Tax Court

Decided July 5, 2011No. Docket No. 30714-08UnpublishedCited by 3 opinions

R determined tax deficiencies and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps' 2001 through 2007 tax years.

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R determined tax deficiencies and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps' 2001 through 2007 tax years. The determinations stem from R's determination that P-H made excess contributions to his Roth individual retirement account (Roth IRA). The parties stipulated Ps' tax deficiencies for the 2001 through 2006 tax years and R conceded all adjustments relating to the 2007 tax year, leaving only the accuracy-related penalties for Ps' 2001 through 2006 tax years in dispute. Held: Ps' are liable for sec. 6662(a), I.R.C., accuracy-related penalties for their 2001 through…

1Opinion of the Court

RONALD V. AND DONNA-KAY SWANSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Swanson v. Comm'r

Docket No. 30714-08.

United States Tax Court

T.C. Memo 2011-156; 2011 Tax Ct. Memo LEXIS 155; 102 T.C.M. (CCH) 6;

July 5, 2011, Filed

Decision will be entered under Rule 155.

R determined tax deficiencies and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps' 2001 through 2007 tax years. The determinations stem from R's determination that P-H made excess contributions to his Roth individual retirement account (Roth IRA). The parties stipulated Ps' tax deficiencies for the…

2Cases cited29 opinions

  1. Freytag v. CommissionerSupreme Court of the United States · 1991
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. United States v. BoyleSupreme Court of the United States · 1985
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967

24 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Wakefield v. Comm'rUnited States Tax Court · 2015
  2. Norman Hinerfeld v. CommissionerUnited States Tax Court · 2019
  3. Norman Hinerfeld v. CommissionerUnited States Tax Court · 2019

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