Mazzei v. Commissioner, 150 TC No. 7 (Mar. 5, 2018): Family Members Liable for Tax on Money Rerouted Through FSC to Roth IRAs

In Celia Mazzei, et al. v. Commissioner, the Tax Court sustained the IRS determination that certain family members were the owners of, and liable for tax on, funds they rerouted from their family business through a Bermuda-based foreign sales corporation and into Roth IRAs that they had established for this purpose.

The court declined to uphold penalties under Section 6651(a) and (b), but held the taxpayers were liable for excise tax under Section 4973 for excess contributions to Roth IRAs.

See full opinion by clicking Celia Mazzei v. Commissioner.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.


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