- 6 - From the record, the remaining $57,617.93, which was deposited into the joint savings and checking accounts, was not readily traceable. However, on November 28, 2001, the balance in the joint savings account was $57,878.32. As stated previously, petitioner and Ms. Glenn reported pension and annuity income of $165,838 on their joint Federal income tax return for taxable year 2001. However, they did not report on their 2001 joint Federal income tax return the 10- percent early withdrawal additional tax imposed by section 72(t). Petitioner concedes that the total amount of $165,838 of pension and annuity income reported on the return is subject to the 10-percent additional tax under section 72(t) on early withdrawals. After the date of the notice of deficiency, petitioner tendered to respondent payment of $8,267, approximately one-half of the amount of the 10-percent additional tax. Petitioner contends that he is not liable for the accuracy- related penalty pursuant to section 6662(a) with respect to the underpayment attributable to the unreported 10-percent additional tax under section 72(t), because the underpayment was a result of an “honest” mistake by his and Ms. Glenn’s tax return preparer. In addition, petitioner requests relief pursuant to section 6015 from liability for one-half of the 10-percent additional taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011