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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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Last modified: May 25, 2011