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Petitioner did not file a timely 1998 Federal income tax
return, and the record does not indicate that petitioner
requested an extension of time to file. Petitioner also did not
file timely income tax returns for years before and after 1998.
Petitioner filed his 1994 return on August 8, 1996, his 1995
return on February 13, 1998, his 1996 return on November 23,
1998, his 1997 return on February 4, 2001, and his 1999 return on
June 6, 2002.
On January 14, 2002, respondent mailed to petitioner a
notice of deficiency with respect to petitioner’s 1998 taxable
year. In the notice of deficiency, respondent determined that
the full amount of the 1998 distribution was includable in his
income. Respondent also determined that petitioner was liable
for an addition to tax under section 6651(a)(1) for failure to
file a timely 1998 income tax return.
On April 8, 2002, petitioner and Mrs. Barkley filed a joint
Form 1040, U.S. Individual Income Tax Return, for 1998. On the
Form 1040, petitioner included the 1998 distribution in gross
income. Petitioner also reported that he owed an additional 10-
percent tax of $14,749 for receiving an early distribution from
the plan.
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