- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011