Joyce M. Thomas - Page 2

                                        - 2 -                                         
                                                                                     
                                  Sec. 6651(a)(1)      Sec. 6654(a)                   
               Year    Deficiency    Additions to tax    Additions to tax             
               1998      $14,664        $791                --                        
               1999      49,065         7,471               $1,343                    
               2000      31,403         5,785               1,187                     
               After concessions,2 the issues for decision are:  (1)                  
          Whether petitioner is liable for a 10-percent additional tax                
          under section 72(t)(1) on distributions made from her individual            
          retirement accounts (IRAs) in 1999 and 2000; (2) whether                    
          petitioner is liable for additions to tax under section                     
          6651(a)(1) for failure to timely file her Federal income tax                
          returns for 1998, 1999, and 2000 (years in issue); and (3)                  
          whether petitioner is liable for additions to tax under section             
          6654(a) for failure to pay estimated income tax for 1999 and                
          2000.                                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time she filed the           
          petition, petitioner resided in Milpitas, California.                       
               Petitioner was born in 1958.  At some point during 1992 or             


               1(...continued)                                                        
          amounts are rounded to the nearest dollar.                                  
               2  In the stipulation of facts, the parties agreed to the              
          amount of income received by petitioner and the deductions                  
          petitioner is entitled to for 1998, 1999, and 2000.                         





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