Agnes T. Bosco - Page 3

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               Respondent determined a deficiency of $3,705.60 in                     
          petitioner’s Federal income tax for 2001 and the section 6662(a)            
          penalty in the amount of $741.12.  At trial, petitioner conceded            
          respondent’s determination of a section 72(t) additional tax of             
          $282 for an early distribution from her qualified retirement                
          plans.  The issues for decision are:  (1) Whether petitioner is             
          entitled to a claimed deduction of $12,449 for moving expenses              
          under section 217, and (2) whether petitioner is liable for the             
          section 6662(a) penalty.                                                    
               Some of the facts were stipulated.  Those facts, with the              
          exhibits annexed thereto, are so found and are made part hereof.            
          Petitioner’s legal residence at the time the petition was filed             
          was Reno, Nevada.                                                           
               During part of 2001, petitioner was employed by Authentic              
          Fitness.  Authentic Fitness manufactured clothing under the                 
          Speedo trade name and was headquartered in California.  Authentic           
          Fitness’s main warehouse was at Reno, Nevada.  Petitioner worked            
          at the Reno warehouse in the international shipping department.             
               Petitioner had been employed by Authentic Fitness for                  
          slightly over 2 years when, in 2001, the company decided to move            
          its warehouse operation to California.  Petitioner and eight                
          other employees transferred to the new location at Irwindale,               
          California, located just outside of Los Angeles.  In connection             
          with the move, Authentic Fitness agreed to pay the employees’               






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