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After concessions,1 the issues for our consideration are:
(1) Whether petitioner is entitled to any Schedule A itemized
deductions for the taxable years 1993 and 1994; (2) whether
petitioner is liable for additional tax under section 722 in 1993
and 1994 for premature distributions of $35,000 and $8,717.32,
respectively, from individual retirement accounts; and (3)
whether petitioner is liable for additions to tax under section
6651(a) for 1993 and 1994 or under section 6654(a) for 1993.
FINDINGS OF FACT3
Petitioner resided at 318 Georgia Circle, Placentia,
California, during the tax years at issue and at the time her
petition was filed. Petitioner was born on January 18, 1941.
Petitioner was employed as a flight attendant for Trans World
Airlines (TWA) from September 1963 until she voluntarily left in
March 1991. During the 1993 and 1994 taxable years, petitioner
maintained a joint checking account at First Interstate Bank with
her sister, Alexandra Robertson, and her mother, Joanne
Robertson.
1 During trial, petitioner conceded all of the unreported
income issues set forth in the two notices of deficiency.
2 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.
3 The stipulation of facts and exhibits attached thereto are
incorporated herein by this reference.
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