- 3 - either section 6651(a)(1) or section 6651(f), and under section 6654 for the years in issue; and (5) whether a penalty should be awarded under section 6673. Respondent has conceded that petitioner is not liable for section 6662(a) accuracy-related penalties as determined in the notice of deficiency for 1989 and as alleged in the Amendment to the Answer for 1990, 1991, and 1992. FINDINGS OF FACT2 At the time the petition was filed, petitioner resided in Crossett, Arkansas. During the years in issue, petitioner was a veterinarian in a sole proprietorship doing business as the Crossett Animal Clinic. Petitioner received adjusted gross income from his veterinary practice of $65,000 in each of the years in issue. In 1992, petitioner had a short-term capital gain of $752.50 from the sale of stock. In 1992, petitioner also received interest income of $35 and dividend income of $65. Petitioner failed to report the income from his veterinary practice, the capital gain, or the interest and dividend income, or to pay Federal income taxes on these amounts. In 1989, petitioner received a $30,000 premature distribution from his individual retirement account (IRA). 2 The stipulation of facts and the attached exhibits are incorporated therein by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011