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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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Last modified: May 25, 2011