Joseph Emilio DiFlora - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency of $5,144 in petitioner’s           
          2000 Federal income tax, an addition to tax of $257 under section           
          6651(a)(1), and an accuracy-related penalty of $1,029 under                 
          section 6662(a).                                                            
               After concessions by the parties as to petitioner’s                    
          unreported interest of $106, and petitioner’s unreported ordinary           
          dividends of $129 and $21, the issues for decision are:  (1)                
          Whether petitioner failed to include in gross income ordinary               
          dividend income in the amount of $18,432; (2) whether petitioner            
          is liable for an addition to tax under section 6651(a)(1); and              
          (3) whether petitioner is liable for an accuracy-related penalty            
          under section 6662(a).                                                      
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Eastchester, New York, at the              
          time he filed his petition.                                                 
               Section 7491(a) does not affect the outcome because                    
          petitioner’s liability for the deficiency is decided on the                 
          preponderance of the evidence.                                              
               During taxable year 2000, petitioner owned 200 shares of               
          Bell Canada Enterprise, Inc. (BCE).  In May 2000, pursuant to a             
          planned “Joint Arrangement” to distribute its Nortel Networks               
          Corp. (Nortel) stock, BCE distributed to petitioner 314 shares of           
          Nortel stock with a fair market value of approximately $18,432.             
               On Form 1099-DIV, Dividends and Distributions 2000,                    






Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011