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Respondent determined deficiencies in petitioner's 1994 and
1995 Federal income taxes in the amounts of $5,813 and $3,036,
respectively. Respondent also determined an addition to tax
under section 6651(a)(1) in the amount of $1,431 for failure to
timely file a 1994 Federal income tax return. Petitioner filed a
timely petition with this Court. At the time of filing the
petition, petitioner resided in Washington, D.C.
The issues for decision are: (1) Whether petitioner is
entitled to deduct claimed Schedule C expenses in amounts in
excess of those allowed by respondent; (2) whether petitioner
failed to report $1,098 in income received from sales of
insurance in 1994; (3) whether petitioner failed to include $440
in income received from a retirement plan distribution in 1994;
(4) whether petitioner is subject to a 10-percent tax on a
premature distribution from a retirement plan in 1994, as
provided under section 72(t); and (5) whether petitioner is
subject to the addition to tax under section 6651(a)(1) for
failure to file a timely Federal income tax return for tax year
1994.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
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