- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011