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respectively. The issues for decision2 are (1) whether
petitioner realized income of $50,000 under section 61(a)(12)
from the discharge of indebtedness; (2) whether she is liable
under section 6651(a)(1) for the addition to tax for late filing;
and (3) whether she is liable under section 6654 for the addition
to tax for failure to pay estimated tax. We hold that petitioner
realized income of $50,000 from the discharge of indebtedness and
that she is liable for the additions to tax.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioner resided in Kearney, Nebraska, when she
filed her petition in this case.
On or before December 31, 1977, petitioner’s mother and
stepfather (the Pattersons) formed Murl Patterson, Inc., a
corporation organized under the laws of the State of Nebraska
(corporation). Thereafter, commencing on or about December 30,
1977, and continuing at least through January 1, 1983, the
Pattersons made a series of gifts of the corporation’s common
stock to their three daughters and their spouses. By January 1,
2Additional issues determined by respondent in the notice of
deficiency and not included by petitioner in the petition are
deemed conceded. See Rule 34(b)(4).
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