Clayton W. Plotkin, (2001)
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Clayton W. Plotkin, (2001)
T.C. Memo. 2001-71
UNITED STATES TAX COURT CLAYTON W. PLOTKIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13365-99. Filed March 23, 2001.Wayne A. Smith, for petitioner.Charles B. Burnett and J. Robert Cuatto, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined a $12,188 deficiency in petitioner's 1994 Federal income tax as well as a $2,437.60 section 6662(a)1 accuracy-related penalty. The first issue for decision is whether the amount which petitioner received as a loan from his employer's pension plan constitutes a taxable distribution under section 72(p). If so, we must determine whether petitioner is liable for the 10-percent additional tax under section 72(t) by reason of such distribution as well as whether petitioner is liable for the section 6662(a) accuracy-related penalty.FINDINGS OF FACT Certain facts have been stipulated and are ...See the full content of this document
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