- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011