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entered is not reviewable by any other court, and this
opinion should not be cited as authority.
Respondent determined a deficiency of $6,268 in
petitioners’ income tax for taxable year 2002. The case
is before the Court at this time to decide a motion for
summary judgment filed by respondent. Petitioners resided
in Emery, South Dakota, at the time they filed their
petition.
The principal adjustment in the notice of deficiency
is an increase of $30,199 in petitioners’ gross income.
According to the notice, this adjustment is based on
a Form 1099-Misc, Miscellaneous Income, issued by the
Campbell v. State Farm Settlement Fund showing that
$30,199 had been paid to Joice Stieber Braden (petitioner)
as “other income” during 2002.
As a consequence of the above adjustment, respondent
determined a decrease in the medical deductions claimed
on Schedule A, Itemized Deductions, of petitioners’ return
for taxable year 2002. Respondent also determined that
petitioners had substantially understated their income tax
for 2002 within the meaning of section 6662(d) and that
petitioners are liable for an accuracy-related penalty of
$1,254 under section 6662(a).
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