Lisa B. Williams - Page 2




                                        - 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.                                                                   




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