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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession by respondent, this Court must decide:
(1) Whether wages, rental income, interest, and individual
retirement account distributions received by petitioner are
taxable; (2) whether petitioner is liable for the addition to tax
under section 72(t) for the early distributions from qualified
retirement plans during the 1996 taxable year; (3) whether
petitioner is liable for an addition to tax under section
6651(a)(1) for the failure to file a tax return for the 1996
taxable year; (4) whether petitioner is liable for additions to
tax under section 6654 for the failure to pay estimated taxes for
the 1995 and 1996 taxable years; (5) whether petitioner is liable
for accuracy-related penalties under section 6662(a) for the
underpayment of taxes for the 1994 and 1995 taxable years; and
(6) whether a penalty should be awarded to the United States
under section 6673.
For clarity and simplicity, we have combined the findings of
fact and conclusions of law. Some of the facts in this case have
been stipulated and are so found. Petitioner resided in Coeur
d'Alene, Idaho, at the time he filed his petitions in this
consolidated case.
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Last modified: May 25, 2011