- 3 - returns to determine a deficiency and additions to tax, using a married filing separately status for petitioner. Petitioner filed a joint 1990 Federal income tax return with his wife on April 15, 1993. On that return, petitioner included all of the payments that respondent had determined were taxable in the notice of deficiency, except for the following: Reported Payor on Form: Amount National Home Life Assurance 1099-R $1,092 Jackson National Life Ins. Co. 1099-R 14,470 Jackson National Life Ins. Co. 1099-INT 53 The total distribution by National Home Life Assurance (National) was $4,426, but respondent contends that only $1,092 was taxable, based on information reported to respondent by National. The $14,470 payment that petitioner received from Jackson National Life Insurance Company (Jackson) was his one- third share of the accumulation value ($43,410) of an annuity that had been purchased by petitioner's mother, who died in 1990 at age 62. Upon his mother's death petitioner became entitled to this payment as a beneficiary under the annuity contract. Jackson reported the $14,470 as the gross distribution to petitioner and did not report what portion of the distribution was taxable. Petitioner's mother acquired the Jackson annuity in a section 1035 exchange for an annuity that she had acquired through United of Omaha. This exchange took place on May 5, 1986. Respondent contends that the $53 payment from Jackson isPage: Previous 1 2 3 4 5 6 7 Next
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