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FAZI v. COMMISSIONER

Docket No. 13874-93.

105 T.C. 436 (1995)

JOHN U. FAZI AND SYLVIA FAZI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 19, 1995.

Attorney(s) appearing for the Case

Paul A. Kasicky, for petitioners.

Julia L. Wahl and Janine H. Bosley, for respondent.

OPINION

VASQUEZ, Judge:

Respondent determined a deficiency in petitioners' 1986 Federal income tax in the amount of $160,904. The deficiency is attributable to the merger of plan 2, a qualified pension plan, into plan 1, an unqualified pension plan, and actual corporate contributions made to unqualified pension plans 1 and 3 on petitioners' behalf.1 The 1986 tax year is open for redetermination only if section 6501(e)...

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