- 7 - indicate the type of plan involved. Petitioner did not include the $1,193 in gross income on his 1996 income tax return. At trial, petitioner acknowledged receiving moneys from Metropolitan Life Insurance Co. and testified that he had a life insurance policy with that insurer. Petitioner contends the distribution he received was a policy loan and, therefore, was not gross income. Petitioner presented no documentary evidence to establish that he had received such a loan. Petitioner agreed that loan proceeds from an insurance policy generally do not constitute gross income, yet, was unable to answer why his insurance company considered $1,193 of the distribution as a taxable amount. The Court concludes that petitioner has not established that the proceeds he received from Metropolitan Life Insurance Co. during 1996 were the proceeds of a loan or that such distributions did not constitute gross income. Respondent, therefore, is sustained on this issue. In the notice of deficiency, respondent determined that petitioner was liable for the accuracy-related penalty under section 6662(a) for negligence or intentional disregard of rules or regulations with respect to the following adjustments: State income tax refund $1,503 Unemployment compensation 748 Form 1099-R, Metropolitan Life Ins. Co. 1,193 Tax withheld by Metropolitan Life Ins. Co. 119Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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