- 2 - 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.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