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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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Last modified: May 25, 2011