- 2 - Respondent determined a deficiency of $20,511 in petitioner’s Federal income tax for 2000 and an accuracy-related penalty of $4,102 under section 6662(a). After concessions,2 the issues for decision to be entered are: (1) Whether $58,000 of the amount that petitioner received from settlement of a lawsuit is excludable from her gross income under section 104(a)(2). We hold it is not excludable. (2) Whether petitioner is liable for an accuracy-related penalty under section 6662(a). We hold she is not liable. Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated into our findings by this reference. Petitioner resided in Pomona, New York at the time she filed the petition in this case. Background Work and Pregnancy Petitioner began work with Liberty Travel, Inc. (Liberty), as a clerical worker on February 2, 1996, and was promoted to operations supervisor within 2 months at an increased rate of 2Respondent concedes petitioner is not liable for the self- employment tax included in the notice of deficiency. Respondent also concedes that, assuming we find that the $58,000 amount is not excludable, petitioner is entitled to an itemized deduction of $20,000 for legal expenses, subject under sec. 67(a) to the 2-percent floor.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011