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account on a monthly basis. Petitioner did not report any income
from the sales of his small business on his tax return for 1997
or any other taxable year.
A number of pension withdrawals were made by petitioner and
Mrs. Parker. In 1997, Mrs. Parker made an early pension
withdrawal in the amount of $39,577 from Putnam Investments.
(All amounts are rounded.) An additional pension distribution
was also made from another pension fund of Mrs. Parker during
1997. Petitioner also received a pension distribution in 1997
from his retirement fund. Pension distributions totaling $43,783
were deposited in the joint money market account during 1997.
Petitioner and Mrs. Parker signed and filed a joint Federal
income tax return for the taxable year 1997. The 1997 return was
prepared by H&R Block. On the 1997 return, line 16a, Total
pensions and annuities, was left blank. Petitioner and Mrs.
Parker reported total income of $22,835 on the 1997 return.
Petitioner and Mrs. Parker divorced on June 13, 1999.
In the notice of deficiency for the 1997 taxable year,
respondent determined that petitioner and Mrs. Parker had
unreported interest income in the amount of $884, nonemployee
compensation in the amount of $100, royalty income in the amount
of $643, and pension income in the amount of $43,783.
Petitioner filed a Form 8857, Request for Innocent Spouse
Relief. Respondent denied petitioner’s request for innocent
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