Dona Elizabeth Conway, petitioner v. Commissioner of Internal Revenue, respondent

From: United States. Tax Court. Reports | Date: December 1, 1998| Author: | Copyright information

Docket No. 22257-96. Filed December 30, 1998.

Held, under the facts of this case, direct transfer of a portion of funds invested in an annuity contract into another annuity contract qualifies as a nontaxable exchange under sec. 1035, I.R.C. Other issues also decided.

Dona Elizabeth Conway, pro se. Blaine C. Holiday, for respondent.

SwIFT, Judge: Respondent determined a deficiency of $123,855 and an addition to tax and a penalty with respect to petitioner's Federal income tax for 1994.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the ...

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