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Respondent determined deficiencies, additions to tax, and
penalties in petitioner’s 1995 and 1996 Federal income taxes as
follows:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1995 $12,222 $378 $2,157
1996 13,809 1,209 1,798
The issues for decision are: (1) Whether a distribution in 1995
to petitioner from the individual retirement account (IRA) of
petitioner’s deceased father is taxable to petitioner; (2)
whether petitioner is entitled to deductions for contributions in
1995 and 1996 to a simplified employer pension-individual
retirement account (SEP); (3) whether petitioner is entitled to
deductions for amounts paid for self-employed health insurance;
(4) whether petitioner is liable for additions to tax for failure
to file timely returns for 1995 and 1996 pursuant to section
6651(a)(1); and (5) whether petitioner is liable for negligence
penalties for 1995 and 1996 pursuant to section 6662(a).1
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition herein, petitioner resided in Fort Washington, Maryland.
1 There are also adjustments to personal exemptions,
itemized deductions, and the alternative minimum tax, which
result from the above adjustments and are otherwise not in issue.
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