Paschall v. Commissioner
United States Tax Court
R determined sec. 4973, I.R.C., excise tax deficiencies and additions to tax under sec. 6651(a)(1), I.R.C., for Ps' 2002 through 2006 tax years. The determinations stem from R's assertion that P-H made excess contributions to his Roth individual retirement account. Held: Ps are liable for the excise tax deficiencies and additions to tax to the extent decided herein.
1Opinion of the Court
Wherry, Judge:
These consolidated cases are before the Court on petitions for redetermination of respondent’s determinations, in notices of deficiency, that petitioners owe excise tax deficiencies and section 6651(a)(1) additions to tax for their 2002 through 2006 tax years as well as an income tax deficiency and a section 6662(a) accuracy-related penalty for their 2005 tax year. 2
The issues for decision are: (1) Whether petitioner husband made an excess contribution to his Roth individual retirement account (Roth IRA) and is liable for section 4973 excise tax deficiencies for the 2002 through…
2Cases cited36 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
31 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- Repetto v. Comm'rUnited States Tax Court · 2012
- Wakefield v. Comm'rUnited States Tax Court · 2015
- Celia Mazzei v. CommissionerUnited States Tax Court · 2018
- David F. Hewitt & Tammy K. Hewitt v. CommissionerUnited States Tax Court · 2020
8 more not listed; retrieve them via the Exa API.