- 3 - interest and penalties, on the income reported by petitioners on their 2000 return have been paid. Petitioners agree that the IRA distribution was includable in gross income. Contrary to this Court's Rules of Practice and Procedure, the parties did not file with the Court a written stipulation of facts. Rule 91. Nonetheless, respondent offered into evidence at trial the necessary documentary information upon which the Court makes its findings of fact and opinion. The facts, as recited, are not in dispute, except petitioners' contention that payments they made to the Internal Revenue Service included the tax on the pension distribution upon which the notice of deficiency is based. The pension plan distribution was evidenced by the issuance by the payor of a Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., filed with the Internal Revenue Service. As noted, petitioners acknowledge receipt of the proceeds of the distribution. Sometime after petitioners filed their 2000 income tax return, they were contacted by collection agents of the Internal Revenue Service relative to the unpaid tax shown on their 2000 tax return as well as unpaid tax for their 2001 tax year. Although petitioners contend that the matter of the IRA distribution was discussed, and they understood that theirPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011