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Docket No. 8627-95
Linda L. Erwin
Additions to tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1993 $4,356 $1,089 $182
The deficiency in income tax for 1992 is based on
respondent's determination that petitioners failed to report the
following items of income:
Item of income Amount
Wages (Hallmark Cards, Inc.) $626
Interest (United Consumers Credit Union) 124
IRA distribution (United Consumer C/U) 56,417
Total 57,167
The deficiency in income tax includes the 10-percent additional
tax imposed by section 72(t) for premature distributions from
qualified retirement plans. The penalty under section 6662(a) is
based on respondent's determination that the underpayment of tax
for 1992 is due to negligence or intentional disregard of rules
or regulations.
Insofar as petitioner Duane B. Erwin is concerned, the
deficiency in income tax for 1993 is based on respondent's
determination that petitioner failed to report on a timely-filed
income tax return for that year: (1) Wages from Hallmark Cards,
Inc., and (2) income from self-employment, as reconstructed by
respondent. The deficiency in income tax includes the self-
employment tax. The addition to tax under section 6651(a) is
based on respondent's determination that petitioner failed to
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