Gregory R. Brown - Page 2

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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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