- 4 - reported adjusted gross income of $69,313.51 for 1997. Among other itemized deductions not at issue herein, petitioners claimed a deduction for a casualty or theft loss of $300,000 in connection with the loss, at the time of petitioner's dismissal from Berkeley, of his employer-sponsored term life insurance policy having a face value of $300,000. Thus, petitioners reported a zero tax liability for 1997, a withholding credit of $14,019.67, and an overpayment of $14,019.67. In the notice of deficiency, respondent determined that petitioners failed to include in income $45,955 in taxable retirement distributions from Berkeley and that the $11,281 distribution from petitioner's Bank of America IRA was taxable. Respondent determined further that petitioners were not entitled to a deduction for the $300,000 casualty or theft loss claimed on their return and that petitioners were liable for the accuracy- related penalty under section 6662(a) for a substantial understatement in tax or for negligence or disregard of rules or regulations in the amount of $3,211.20. The first issue is whether petitioners failed to include in income $45,955 in taxable retirement plan distributions for the year at issue identified above as the U. of California Benefits Program. Beginning in February 1997, petitioner began receiving monthly pension checks of $5,579.83 from the University of California totaling $61,378.13 for the year (the pensionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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