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During 1992, petitioner maintained an interest bearing
checking account at the First Valley Bank. For years prior to
the year in issue, he received refunds of Federal income taxes,
sometimes amounting to thousands of dollars.
Respondent's Information Return Master File (IRMF)
transcript indicates that several payors issued information
returns to petitioner for the taxable year 1992 as follows:
Type of
Payor Form income Amount
Geiger's Bvgs., Inc. 1099B S-T cap. gains $15,282
First Valley Bank 1099-INT Interest 34
U.S. Treasury Dept. 1099-INT Interest 16
Manufacturer's Life 1099R Taxable distr. 1,771
In the notice of deficiency issued to petitioner on November
20, 1996, respondent determined that petitioner must include the
above items of income (the items of income) in his 1992 income.
In computing his 1992 taxable income, respondent took the items
of income into account and allowed petitioner a personal
exemption deduction and the standard deduction appropriate for a
married individual who files a separate return. Petitioner's
1992 Federal income tax liability and the deficiency here in
dispute were computed by application of the applicable rate of
Federal income tax to petitioner's taxable income and adding to
that amount the additional tax imposed by section 72(t) on the
distribution from Manufacturer's Life. Respondent further
determined that petitioner is liable for the addition to tax
under section 6651(a) for his failure to file a 1992 Federal
income tax return.
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