Margie E. Robertson - Page 2

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          Principal and accrued interest were payable upon the transfer of            
          the property or death of Ms. Moore, whichever came first.  In               
          1998, Ms. Moore died.  Petitioner, on her 1999 Federal income tax           
          return, reported a $25,000 loss.                                            
               From 1992 to 2000, petitioner was employed by the City of              
          Seattle (the City) as a license and standards inspector.  During            
          this period she had a digestive disorder.  Although petitioner              
          could not eat during work hours, her digestive disorder imposed             
          no other physical limitations on her ability to work.  In 1999,             
          petitioner requested to have her schedule modified from a 10 1/2-           
          hour workday (i.e., with a 1/2-hour lunch break) to a 10-hour               
          workday without a lunch break.  The City denied petitioner’s                
          request.  In response, on August 1, 2000, petitioner resigned.              
          After petitioner resigned, the City granted her request, but she            
          did not accept their accommodation.                                         
               In 2000, petitioner received a $46,996 Individual Retirement           
          Account (IRA) distribution.  Petitioner reported the distribution           
          on her 2000 Federal income tax return and paid income tax                   
          relating to the gross amount but did not pay the 10-percent                 
          additional tax pursuant to section 72(t)(1).                                
               By notice of deficiency dated December 31, 2002, respondent            
          determined deficiencies of $4,382 and $4,700 relating to 1999 and           
          2000, respectively.  On April 4, 2003, petitioner, while residing           
          in Memphis, Tennessee, filed her petition with this Court.                  






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