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Respondent determined a deficiency of $20,453 in
petitioners' Federal income tax for 1997 and an accuracy-related
penalty under section 6662(a) of $3,211.20.
The issues for decision are: (1) Whether petitioners failed
to include in income distributions from various employee
retirement plans of Wallace F. Smith (petitioner) during the year
at issue; (2) whether petitioners are entitled to a deduction for
a casualty or theft loss of $300,000; and (3) whether petitioners
are liable for the accuracy-related penalty under section
6662(a).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was Walnut Creek, California.
Petitioner has a bachelor's degree in economics from Yale
University, a master's degree in economics from the University of
Connecticut, and a Ph.D. in economics from the University of
Washington. He began teaching economics at the University of
California at Berkeley (Berkeley) in 1959 and continued teaching
there, in the Haas School of Business, until January 1997. At
that time, petitioner was dismissed from Berkeley after declining
the opportunity to resign or retire voluntarily. Although the
circumstances surrounding petitioner's dismissal from Berkeley
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