- 2 -- 2 -
The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined a deficiency of $7,884 in petitioners'
1999 Federal income tax and an accuracy-related penalty of
$1,577. After concessions,1 the issues remaining for decision
are: (1) Whether petitioners received unreported income; (2)
whether petitioners are subject to additional tax for an early
distribution from a qualified retirement plan; and (3) whether
petitioners are liable for the accuracy-related penalty due to
negligence.
Background
Some of the facts have been stipulated and are so found.
The exhibits received into evidence are incorporated herein by
reference. At the time the petition in this case was filed,
petitioners resided separately in Northampton, Massachusetts.
Petitioner Manuel Francisco Palomo is an attorney.
Petitioner Jane L. Potter organized and directed the Parent
Teacher Organization's (PTO) after-school program at Smith
College Campus School (Smith). In 1999, Ms. Potter was in charge
of the program, planned individual sessions, and was responsible
1 In the notice of deficiency respondent determined that
petitioners were liable for additional tax relating to the
failure to include income from Norman Ross Publishing, Inc.; for
unreported distributions from a qualified retirement plan; for an
unreported Mass. State tax refund; and, for unreported interest
earned from a bank account. These issues have been resolved by
the parties.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011