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Ross M. Greenberg, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: Respondent determined a
deficiency in petitioners' 1996 Federal income tax in the amount
of $3,462 and a section 6651(a)(1) addition to tax in the amount
of $866. Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
As admitted by petitioners in the Stipulation of Facts, with
respect to their untimely 1996 Federal income tax return, Mrs.
Labato underreported income from her employment by Marriott
International, Inc., and totally omitted income from Columbia
Park Medical Center; petitioners failed to report some of their
interest income from a bank; and each petitioner underreported
Social Security benefits each received in 1996. Respondent
concedes that petitioners are not liable for the additional tax
of $2,118 on an early distribution from a qualified pension.
This Court must decide whether petitioners are liable for the
addition to tax under section 6651(a)(1) for failure to timely
file their tax return.
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