- 3 -
(2) For the taxable year 1990, respondent determined a
deficiency in petitioners' income tax, as well as a deficiency in
petitioners' excise tax under section 4980A, in the total amount
of $15,669. The 10-percent additional tax imposed by section
72(t) constitutes the deficiency in income tax.4
In her amended answer, respondent asserted deficiencies in
petitioners' income tax and excise tax under section 4980A for
the taxable year 1990 in the total amount of $19,394, an increase
in the amount of $3,725 over the total determined in the notice
of deficiency.5
Total deficiencies in income and excise taxes 73,905
4 Again, the notice of deficiency is not a model of clarity.
However, the deficiencies determined therein for the taxable year
1990 are as follows:
Deficiency in income tax
-- under sec. 72(t) $15,446
Deficiency in excise tax
-- under sec. 4980A 223
Total deficiencies in income and excise taxes 15,669
5 The increase consists of the following:
Deficiencies
Income/excise tax Statutory notice Amended answer Increase
Section 1 --- $3,302 $3,302
Section 72(t) $15,446 15,728 282
Section 4980A 223 364 141
$15,669 $19,394 $3,725
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Last modified: May 25, 2011