LOWE v. COMMISSIONER OF INTERNAL REVENUE

No. 23670-08.

T.C. Memo. 2011-106

FREDRIC J. AND DUSHANKA LOWE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 19, 2011.


Attorney(s) appearing for the Case

David R. Bosse and Mary L. Harriss , for petitioners.

Kathleen A. Tagni , for respondent.


MEMORANDUM OPINION

LARO, Judge.

This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121.1 Respondent determined a $50,252 deficiency in petitioners' 2003 Federal income tax and a $10,050 accuracy-related penalty under section 6662(a). The deficiency largely arises from the distribution of a cash value life insurance policy (policy) from a nonexempt employee trust to petitioner Frederic...

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