Katherine A. Weir - Page 2




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                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  By notice of deficiency dated January 22,             
          1999 (the notice), respondent determined deficiencies in,                   
          additions to, and penalties with respect to, petitioner’s 1994              
          and 1995 Federal income taxes as follows:                                   
                               Additions to Tax/Penalty Under                         
          Year   Deficiency    Sec. 6651(a)    Sec. 6654     Sec. 6662(a)             
          1994     $4,662     $431                $31            $932                 
          1995      4,788     2,765          468                 --                   
          Respondent has since conceded the section 6651(a) addition to tax           
          for 1995.  We accept that concession.  Besides the remaining                
          additions to tax and penalty, the issue for decision is whether             
          there are deficiencies in tax on account of petitioner’s omission           
          from income of certain payments, characterized by respondent as             
          “Pension Income”.  This case has been submitted for decision                
          without trial, pursuant to Rule 122.  Facts stipulated by the               
          parties are so found.  The stipulation of facts filed by the                
          parties, with attached exhibits, is included herein by this                 
          reference.                                                                  
               Unless otherwise indicated, all 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.                                                                  










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