- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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