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MARTIN v. COMMISSIONER

Docket No. 6240-93.

67 T.C.M. 2960 (1994)

T.C. Memo. 1994-213

Marshall H. Martin v. Commissioner.

United States Tax Court.

Filed May 12, 1994.

Attorney(s) appearing for the Case

Marshall H. Martin, pro se. Kenneth L. Bressler, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined that petitioner is liable for Federal excise taxes under section 4973(a) for taxable years 1989 and 1990, resulting in deficiencies of $3,915 and $3,570, respectively.

The issue is whether funds in petitioner's individual retirement accounts (IRA) on December...

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