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Federal income tax and additions to tax under sections 6651(a)(1)
and (2) and 6654(a) in the respective amounts of $1,030.27,
$618.16, and $246.68 for the 1997 tax year.
In two written stipulations, all of the issues have been
settled except the following: (1) The amount of petitioner's
basis, under section 1012, in stock of General Electric Co. (GE),
which petitioner sold or converted into cash during 1997; (2)
whether petitioner is entitled to a deduction under section
162(a) for educational expenses; and (3) whether petitioner is
liable for the additions to tax.
As noted, some of the facts were stipulated. Those facts,
with the annexed exhibits, are so found and are incorporated
herein by reference. At the time the petition was filed,
petitioner was a legal resident of Los Angeles, California.
Petitioner did not file a Federal income tax return for
1997. He engaged in several transactions that year in which
gains and losses were realized. By stipulation, the gains or
losses from all but one of the transactions have been agreed to.
The unagreed transaction relates to an account petitioner
maintained with GE that was generally referred to as a dividend
reinvestment plan. Petitioner could (and did) contribute money
from time to time that was used to purchase stock in GE, and the
dividends from such stock were also used to purchase additional
GE stock. Under the account plan, GE issued fractional shares if
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