- 5 -
return. On line 16a petitioner entered $22,413,2 which is
apparently the sum of the $15,322.69 and $7,089.95 distributions.
He reported $8,613 on line 16b as income. While it appears that
the $8,613 represents the sum of the $7,089.95 loan distribution
and $1,532 of the $15,322.69 distribution, the total of those two
amounts is $8,621.95. The record does not explain this
apparently erroneous computation. However, petitioner does not
dispute receipt of either distribution.
Petitioner did not report the $7,000 distribution on the
return. Respondent, however, received an information return from
ING, indicating a $7,000 distribution to petitioner from the
Eagle retirement plan.
On December 29, 2003, respondent issued a notice of
deficiency. Petitioner timely filed a petition on April 21,
2004.
The primary adjustment in dispute as set forth in the notice
of deficiency is the increase in pension and annuity income as
follows:
2001 Return
Shown on Proposed changes Proposed change
return by IRS to income
Pension & annuity $8,613 1$29,412 $20,799
1 The adjustment includes two distributions from Merrill Lynch and one
distribution from ING.
2 Amount rounded to the nearest dollar.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011