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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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