Interesting Court Cases

Service Center Advice 200148051- (December 2001) IRS concludes that a Roth IRA conversion that failed when IRS determined two years later that the taxpayer's modified Adjusted Gross Income exceeded the conversion threshold, had to be treated as a regular IRA distribution, triggering various taxes and penalties.

Ferreira v. Commissioner; T.C. Memo. summary opinion 2001-167 Argued that tax advice from the IRS should be held valid and accountable. Tax Court found for IRS stating IRS advice does not have the force of law.

Tully v. Commissioner; T.C. Memo. 1999-422; No. 16008-98 (December 27, 1999) Tax evasion promoter who established exempt organizations for individuals was liable for the fraud and failure-to-file penalties, and on its own motion, assessed the maximum section 6673 penalty for abuse and delay.

Snyder v. Department of State Revenue; Cause No. 49T10-9806-TA-70 (January 21, 2000) Argued that wages are not income under either Indiana law or the Internal Revenue Code.

Bibbs v. United States; 85 AFTR2d Par. 2000-348; No. 99-5117 (January 11, 2000) Argued that as Ohio private citizens they are not subject to U.S. income taxation.

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