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Year Return Date Tax Withholding Overpayment
1987 5/11/95 $5,515 $7,208 $1,693
1988 5/13/95 5,366 10,328 4,952
1990 1/15/96 5,564 6,919 1,355
1990 2/26/96 6,709 6,919 210
1990 3/15/96 5,942 6,919 977
1991 5/15/95 2,321 3,039 718
1992 5/16/95 0 2,563 2,563
The parties agree that if respondent prevails on the issues as
stated below, the revised deficiencies and additions to tax will
be as follows:
Addition to Addition
Statutory Deficiency/ Tax to Tax
Year Deficiency (Overpayment) Sec. 6651(a) Sec. 6654
1987 $ 5,515 ($1,693) $ 0 $ 0
1988 5,366 (4,952) 0
1990 12,328 5,409 1,352 305
1991 2,321 (718) 0 0
1992 4,114 1,551 388 55
Petitioners concede that the overpayments are barred by section
6511(b)(2)(B).
We must decide the following issues:
(1) Whether petitioners are required to include, as ordinary
income, the entire distribution of $25,313.22 received by James
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Last modified: May 25, 2011