- 2 -
is not reviewable by any other court, and this opinion should not
be cited as authority.
Respondent determined deficiencies of $5,939, $5,472, and
$4,318 in petitioners’ Federal income taxes for 1999, 2000, and
2001, respectively. Respondent also determined an accuracy-
related penalty under section 6662(a) in the amount of $863 for
2001. The issues for decision are: (1) Whether Mario O. Garza
(petitioner) received income from American Income Life Insurance
Co. (American Life) during 1999, 2000, and 2001 under section
61(a); (2) whether petitioner is liable for self-employment
taxes for 1999, 2000, and 2001 under section 1401(a); and (3)
whether petitioners are liable for the accuracy-related penalty
for 2001 under section 6662(a) for negligence, disregard of rules
or regulations, or a substantial understatement of income tax.2
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made a part hereof.
Petitioners’ legal residence at the time the petition was filed
was Fresno, California.
At the time of trial, petitioner and his wife, Elsie R.
Garza (Ms. Garza), were seeking a divorce. However, they were
2Respondent did not determine any penalty for the years 1999
or 2000. Additionally, in the notice of deficiency, some of
petitioners’ itemized deductions for the 3 years at issue were
disallowed. The notice of deficiency states that petitioners
agreed to those adjustments. Petitioners did not challenge these
adjustments at trial.
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