Fred Henry - Page 2




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          penalty under section 6662(a) on petitioner's Federal income tax             
          (tax), as follows:                                                           
                                                                                      
               Year Deficiency Additions to Tax  Accuracy-Related Penalty              
               1992    $47,092        $11,773                   --                     
               1994    664,931        33,247                 $132,986                  

               The issues for decision are:                                            
               (1)  Is the $150,000 payment that petitioner received from              
          E.I. du Pont de Nemours & Company, Inc. (du Pont) in 1992 in-                
          cludible in his income for that year?  We hold that it is to the             
          extent stated herein.                                                        
               (2)  Are the payments totaling $1,623,203 that petitioner               
          received from du Pont in 1994 excludible from his income for that            
          year under section 104(a)(2)?  We hold that they are not.                    
               (3)  Is petitioner liable under section 6651(a)(1) for 1992             
          for his failure to file a tax return for that year and for 1994              
          for his failure to file timely his 1994 return?  We hold that he             
          is not so liable for 1992 and that he is so liable for 1994.                 
               (4)  Is petitioner liable under section 6662(a) for 1994 for            
          the accuracy-related penalty?  We hold that he is.                           
                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.                










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