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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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