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BERNARD v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5787-10.

T.C. Memo. 2012-221

ROBERT L. BERNARD AND DIOLINDA B. ABILHEIRA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed August 1, 2012.

Attorney(s) appearing for the Case

Robert L. Bernard and Diolinda B. Abilheira , pro sese.

Randall G. Durfee , Ashley V. Targac , and Paul C. Feinberg , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined a deficiency of $44,643 and a section 6662 penalty of $8,179 in relation to petitioners' Federal income tax for 2007. After concessions, the issues for decision are whether distributions petitioners received from various individual retirement accounts (IRAs) are taxable as ordinary income and whether petitioners are liable for the section 6662 penalty. All...

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