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Penalty
Year Deficiency Sec. 6662(a)
1993 $7,000 $1,400
1994 10,437 2,087
1995 10,725 2,145
The controversy between the parties presents the following issues
for our consideration: (1) Whether the amounts of $25,000,
$35,000, and $35,000, received from her employer for 1993, 1994,
and 1995, respectively, were gifts or income that petitioner
failed to report; (2) whether the period for assessment had
expired with respect to petitioner’s 1993 and 1994 tax years at
the time of the mailing of the notice of deficiency; (3) whether
$1,300 received by petitioner’s husband was wages or an early
distribution from a qualified pension plan; and (4) whether
petitioner is liable for an accuracy-related penalty for 1993,
1994, or 1995 under section 6662(a).1
FINDINGS OF FACT2
Petitioner Lisa B. Williams3 resided in Littleton, Colorado,
at the time her petition was filed. After receiving training at
the University of Wisconsin, Health Sciences Center and during
1 All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2 The parties’ stipulation of facts is incorporated by this
reference.
3 At the time of filing the petition, petitioner’s surname
was Williams. At the time of trial, petitioner’s surname was
Bruehahn.
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Last modified: May 25, 2011