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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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Last modified: May 25, 2011