Otis L. Pimpleton and Tabitha Pimpleton - Page 3

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         is not reviewable by any other court, and this opinion should not            
         be cited as authority.                                                       
              Respondent determined a deficiency in, and an accuracy-                 
         related penalty under section 6662(a) on, petitioners’ Federal               
         income tax for 2002 in the amounts of $2,355 and $244.60,                    
         respectively.                                                                
              After concessions by the parties,2 the issue for decision by            
         the Court is whether petitioners underreported on their income               
         tax return for 2002 tips received by petitioner Otis L. Pimpleton            
         during that year.                                                            
              Whether petitioners are entitled to the additional child tax            
         credit as claimed on their return is purely a mechanical matter.             
                                     Background                                       
              Some of the facts have been stipulated, and they are so                 
         found.                                                                       
              At the time that the petition was filed, Otis L. Pimpleton              
         (petitioner) and Tabitha Pimpleton (collectively, petitioners)               
         resided in Las Vegas, Nevada.                                                



               2  Petitioners concede that petitioner Tabitha Pimpleton               
          received unemployment compensation during 2002 in the amount of             
          $3,867, which was not reported on their income tax return for               
          that year.  Respondent concedes that $580 of Federal income tax             
          was withheld from such unemployment compensation, which tax was             
          not claimed by petitioners on their return.  Respondent also                
          concedes, for technical reasons, that petitioners are not liable            
          for the accuracy-related penalty under sec. 6662(a).                        





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