Daniel F. Monte - Page 3

                                        - 2 -                                         
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           
               Respondent determined an accuracy-related penalty under                
          section 6662(a) of $2,900 with respect to petitioner’s Federal              
          income tax for the taxable year 2000.                                       
               The only issue for decision is whether petitioner is liable            
          under section 6662(a) for an accuracy-related penalty.  We hold             
          that he is not.                                                             
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  We incorporate by reference the parties’ stipulation of             
          facts, supplemental stipulation of facts, and accompanying                  
          exhibits.                                                                   
               At the time that the petition was filed, petitioner resided            
          in Buffalo, New York.                                                       
               Petitioner and his former spouse were married in August                
          1982.  They had three children from their marriage, born in                 
          October 1983, March 1987, and June 1990.                                    
               Petitioner has been a mortgage broker for more than 20 years           
          and is a senior vice president at a mortgage banking company.               
          During their marriage, petitioner’s former spouse was a                     
          homemaker.                                                                  
               At all relevant times, petitioner has maintained several               
          brokerage accounts, solely in his name, at First Albany Capital             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011