- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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