- 2 - After concessions by the parties, the issues for our decision for the taxable year 1990 are: (1) Whether petitioners received a taxable distribution from Mrs. Hobson’s retirement plan, and if so, whether petitioners are liable for the additional tax under section 72(t) for an early distribution from such plan. We hold that the 1990 distribution was taxable, and petitioners are subject to the additional tax under section 72(t). (2) Whether petitioners are liable for an addition to tax under section 6651(a) for failure to timely file their 1990 income tax return. We hold that they are not. (3) Whether petitioners are liable for an accuracy-related penalty under section 6662(a) due to a substantial understatement of income tax. We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein. Petitioners resided in Milwaukee, Wisconsin, at the time the petition was filed. Petitioners filed a joint Federal income tax return for taxable year 1990 on October 28, 1991. All references to petitioner in the singular refer to Patricia A. Hobson. 1(...continued) Procedure.Page: Previous 1 2 3 4 5 6 7 Next
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