Timothy J. Glenn - Page 7

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               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 tax                







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