Judith M. De Shon and Michael J. De Shon - Page 3

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          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for the taxable year 2001 of $5,101 and an accuracy-             
          related penalty under section 6662(a) of $1,020.                            
               After dismissal of petitioner Judith M. De Shon2 and after             
          concessions,3 the issues for decision are:                                  
          (1)  Whether petitioners received unreported discharge of                   
          indebtedness income of $12,253 in taxable year 2001.  We hold               
          that they did to the extent provided herein.                                
          (2)  Whether petitioners are liable under section 6662(a) for an            
          accuracy-related penalty.  We hold that they are not.                       






               2  Petitioner Judith M. De Shon (Mrs. De Shon) did not                 
          appear at trial and did not execute the stipulation of facts.               
          Petitioner Michael J. De Shon (Mr. De Shon) is not admitted to              
          practice before this Court and is therefore not authorized to               
          represent Mrs. De Shon in this Court notwithstanding a purported            
          durable power of attorney.  See Rules 24, 200.  Accordingly, the            
          Court will dismiss this action as to Mrs. De Shon.  Rule 123(b).            
          Decision, however, will be entered against Mrs. De Shon                     
          consistent with the decision entered against Mr. De Shon as to              
          the deficiency and the accuracy-related penalty.                            
               3  Respondent concedes that petitioners did not receive                
          Social Security benefits of $246.  Petitioners concede that they            
          received:  (1) Social Security benefits of $6, (2) interest                 
          income of $58 from Catholic Aid Association (Catholic Aid), (3) a           
          taxable distribution of $6,611 from Catholic Knights Insurance              
          Society, and (4) a taxable distribution of $3,001 from Catholic             
          Aid.                                                                        




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