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and adopts the opinion of the Special Trial Judge that is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax and an accuracy-
related penalty pursuant to section 6662(a) for the taxable year
1991 in the respective amounts of $9,772 and $1,954.
The issues are: (1) Whether a distribution from a qualified
retirement plan is includable in petitioners' gross income; (2)
whether petitioners are liable for an additional tax on the
distribution pursuant to section 72(t); (3) whether petitioners
are liable for an accuracy-related penalty pursuant to section
6662(a) for negligence; and (4) whether this Court has the
jurisdiction to redetermine respondent's interest computation in
this case.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference.
Petitioners resided in Evans, Georgia, at the time they
filed their petition in this case. The term "petitioner" refers
to Timothy W. Coffield.
Petitioner was born in Pittsburgh, Pennsylvania, in 1955.
He lived in Pittsburgh and worked for Westinghouse Electric Co.
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