- 13 - before October 31, 2000. Petitioner merely endorsed the check over to Southern Farm Bureau. In the notice of deficiency and accompanying explanations, respondent determined that petitioners failed to include on their original and amended returns the taxable annuity proceeds of $61,548.12 Respondent adhered to the $6,154.94 penalty that petitioners self-assessed on their amended return for the $61,549.38 taxable portion of early distributions by Southern Farm Bureau and Glenbrook. Respondent included the previously unreported SFB and Glenbrook distributions as gross income, determined that self-employment tax was due, and allowed a corresponding deduction for one-half of such tax. Respondent reduced petitioners’ exemptions deduction under section 151(d) because of adjusted gross income greater than $189,950. Finally, respondent determined that a 20-percent accuracy-related penalty was due for substantial understatement of tax under section 6662(a). The first issue is whether petitioners received taxable annuity proceeds of $61,548. Section 61(a)(9) provides that 12 The combined amount of taxable annuity proceeds reported on Forms 1099-R by Southern Farm Bureau and Glenbrook is actually $61,549.38. Respondent admitted a $1.38 error in petitioners’ favor on the amount of annuity proceeds includable as income and did not seek an increased deficiency.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011