Celia Mazzei v. Commissioner

150 T.C. No. 7

UNITED STATES TAX COURT CELIA MAZZEI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ANGELO L. MAZZEI AND MARY E. MAZZEI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 16702-09, 16779-09. Filed March 5, 2018. Ps entered into a prepackaged plan to save taxes by routing funds from their family business through a Bermuda-based foreign sales corporation (FSC) and then into Roth IRAs created for this purpose. Pursuant to this plan, in 1998 each P directly contributed $2,000, the applicable contribution limit, to his or her newly created Roth IRA,…