- 2 - a penalty should be imposed against petitioner under section 6673(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background The facts in this case have been deemed stipulated pursuant to Rule 91(f). Petitioner was a resident of Morristown, Arizona, at the time that the petition in this case was filed. During 1995, petitioner received interest income totaling $48 and an Arizona tax refund of $755. He received a distribution of $13,586 from an individual retirement account. Petitioner’s age did not exceed 59-1/2 at the time of the distribution. During 1995 and 1996, petitioner was employed by Arizona Public Service Co. He received compensation of $64,090.49 in 1995 and $68,123 in 1996 from Arizona Public Service Co. The Arizona Public Service Co. withheld $4,088.67 from petitioner’s wages in 1995 and $5,649.98 from petitioner’s wages in 1996. Petitioner submitted to the Internal Revenue Service documents purporting to be 1995 and 1996 Federal income tax returns. Those documents reported petitioner’s compensation earned in each year and then deducted the equivalent amount asPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011