Horvath v. Commissioner
United States Tax Court
Held, petitioners are not entitled to a deduction for a contribution made by petitioner Virginia R. Horvath to an IRA, under sec. 219, I.R.C. 1954. Held, further, interest income earned on the IRA is not includable in petitioners' gross income. Held, further, petitioners have failed to prove that $ 133.21 originally reported by them as taxable income is not subject to tax.
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Held, petitioners are not entitled to a deduction for a contribution made by petitioner Virginia R. Horvath to an IRA, under sec. 219, I.R.C. 1954. Held, further, interest income earned on the IRA is not includable in petitioners' gross income. Held, further, petitioners have failed to prove that $ 133.21 originally reported by them as taxable income is not subject to tax. Held, further, petitioners are liable for an addition to tax for failure to timely file their 1976 income tax return, under sec. 6651(a).
1Opinion of the Court
Irwin, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the year 1976 in the amount of $549 and an addition to tax under section 6651(a)1 in the amount of $22. Petitioners concede that respondent properly made an adjustment entitled "Taxes — State and Sales” in the amount of $133 in the notice of deficiency issued to them. Petitioners have amended their petition, by asserting that they incorrectly reported as income certain amounts: $161.19 received from U.S. Steel Corp. and $133.21 received from Bethlehem Steel. Respondent has conceded that the $161.19 should…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Fischer v. CommissionerUnited States Tax Court · 1968
- Orzechowski v. CommissionerUnited States Tax Court · 1978
- Richard W. And Janet Orzechowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- John F. Foulkes and Joyce A. Foulkes v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1981
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3Cited by18 opinions
- Anthes v. CommissionerUnited States Tax Court · 1983
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- Orvis v. CommissionerUnited States Tax Court · 1984
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