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is not reviewable by any other court, and this opinion should not
be cited as authority.
Respondent determined a deficiency of $1,100 in petitioners’
Federal income tax for the year 2000.
At the time the petition was filed, petitioners' legal
residence was Preston, Idaho.
Petitioners filed a Federal income tax return for the year
2000 that showed a tax liability of $5,231, an estimated penalty
of $42, and a withholding credit of $777. Petitioners did not
pay the $4,496 balance at the time they filed their return.
During the year 2000, petitioners received an early distribution
from an individual retirement account (IRA) in the amount of
$4,402. Petitioners did not include the $4,402 as income on
their tax return. After being contacted by the collection
division of the Internal Revenue Service, petitioners made
arrangements to pay their tax liability in a series of
installments. Petitioners contend that, in their negotiations
for the installment arrangement, it was their understanding that
the income tax due on the IRA was included in the total amount
they were to pay to the Internal Revenue Service. The sole
issue, therefore, is whether petitioners paid the $1,100
deficiency, which is the tax due on the IRA distribution they
received during the year 2000. Respondent agrees that, except
for the $1,100 attributable to the IRA, the taxes, including
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