Blaney H. Howle III and Polly T. Howle - Page 3




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          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          
               Respondent determined a deficiency of $5,000 in petitioners’           
          1997 Federal income tax.  The issues for decision are:                      
          (1) Whether respondent subjected petitioners to multiple audits             
          for their 1997 taxable year in violation of section 7605(b); and            
          (2) whether respondent determined petitioners’ 1997 Federal                 
          income tax correctly.                                                       
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioners resided in                   
          Florence, South Carolina, at the time their petition was filed              
          with the Court.                                                             
               Petitioners are husband and wife.  Petitioner Blaney H.                
          Howle III (Mr. Howle) turned 62 on October 31, 1997, and                    
          petitioner Polly T. Howle (Mrs. Howle) turned 62 on March 1,                
          1997.  Mr. Howle has been retired on disability from railroad               
          employment since the age of 57.                                             
               In 1997, Mr. Howle received Tier 1 railroad retirement                 
          benefits of $1,186, and Mrs. Howle received Tier 1 railroad                 
          retirement benefits of $284.  Mr. Howle also received $23,083.28            
          in Tier 2 railroad retirement benefits and $516 in supplemental             
          annuity benefits.  Mr. Howle’s employee contributions toward                
          Tier 2 benefits total $20,365.56.  In 1997, Mrs. Howle received             






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