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whether the Court should impose a penalty under section 6673.
Unless otherwise indicated, all section references are to the
Internal Revenue Code for the relevant year. Amounts are rounded
to the nearest dollar.
Background
All of the facts have been stipulated. The stipulated facts
and the attached exhibits are incorporated herein by this
reference. Petitioner resided in Coraopolis, Pennsylvania, at
the time he filed the petition.
During 1998, petitioner was paid $49,859 as an employee of
U.S. Airways. Additionally, in 1998, petitioner received $29,091
as a distribution from a qualified retirement plan with Capital
Guardian Trust Co., and $39 in interest from the U.S. Airways
Federal Credit Union.
Petitioner timely filed a Form 1040, U.S. Individual Income
Tax Return, for 1998, reporting a tax liability of zero and
income taxes withheld of $9,804. As a result, petitioner
requested a refund of $9,804. On October 11, 2000, respondent
sent petitioner a notice of deficiency, determining a deficiency
of $20,099 and a penalty under section 6662(a)(1) and (d)(1).
After petitioner failed to file a petition with the Court in
response to the notice of deficiency, respondent assessed the tax
and penalty.
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