Teri Geisen Rooks - Page 2

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          whether petitioner is entitled to a refund of overpayments                  
          respondent applied to her 1992 tax liability.                               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               In 1992, petitioner married John F. Izzi.  Petitioner and              
          Mr. Izzi filed a joint Federal income tax return for 1992 (1992             
          return).                                                                    
               Respondent examined the 1992 return.  Respondent determined            
          a $7,058 deficiency and an $823 addition to tax2 for 1992.  The             
          deficiency and addition to tax resulted from early distributions            
          from petitioner’s pension and Mr. Izzi’s pension during 1992--              
          petitioner’s taxable distribution was $13,378 and Mr. Izzi’s                
          taxable distribution was $16,026.  Of the additional $7,881                 
          respondent determined was due, 45.5 percent ($3,585.86) was                 
          attributable to petitioner’s pension distribution and 54.5                  
          percent ($4,295.14) was attributable to Mr. Izzi’s pension                  
          distribution.  Ultimately, petitioner agreed to respondent’s                
          determination (i.e., that a $7,058 deficiency and an $823                   
          addition to tax were due for 1992).                                         



               2  From the record, it is unclear whether this was an                  
          addition to tax or a penalty.  The parties stipulated that it was           
          an addition to tax.  For clarity, we shall refer to this amount             
          as an addition to tax.                                                      




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