- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011