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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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