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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 as
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