Albert R. Cujas, Jr., & Susan W. Cujas - Page 2

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            1992              $13,005                  $3,251                   $457                     
            1993              5,172                          1,293              217                      

                                           Susan W. Cujas                                                
                                                             Additions To Tax                            
            Year              Deficiency               Sec. 6651(a)(1)  Sec. 6654(a)                     
            1992              $4,528                   $1,132                   $127                     
            1993              5,172                          1,293              217                      
                  All section references are to the Internal Revenue Code in                             
            effect for the years in issue, and all Rule references are to the                            
            Tax Court Rules of Practice and Procedure.  The issues for                                   
            decision are as follows:                                                                     
                  1.  Whether petitioners failed to report income.  We hold                              
            that they did to the extent provided below.                                                  
                  2.  Whether petitioners, pursuant to section 72(t), are                                
            liable for a 10-percent additional tax on early distributions                                
            they received in 1992 from their individual retirement accounts                              
            (IRA's).  We hold that they are liable.                                                      
                  3.  Whether petitioners, pursuant to section 1401, are                                 
            liable for self-employment tax.  We hold that they are liable to                             
            the extent provided below.                                                                   
                  4.  Whether petitioners, pursuant to section 6651(a)(1), are                           
            liable for additions to tax for failure to file timely Federal                               
            income tax returns.  We hold that they are liable to the extent                              
            provided below.                                                                              







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