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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.
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