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proceed with collection of their Federal income tax liabilities
for the 2000 tax year.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioners’ legal residence at the time the petition was filed
was Laplace, Louisiana.
Petitioners live and work in Louisiana. Mrs. Carter was not
employed during 2000. Mr. Carter retired from Kaiser Aluminum on
January 14, 1999, after being employed there for 30 years. Mr.
Carter exercised an early retirement payout during a strike.
During 2000, Mr. Carter received retirement benefits in the form
of a $750 per month pension from Frank Russel Trust Co.2 Mr
Carter also received a cash payout for saved vacation time. The
record does not reflect the exact amount of this payout.
Petitioners filed a timely joint Federal income tax return
for 2000. On the return, petitioners failed to include as gross
income the retirement benefits Mr. Carter received that year.
On November 4, 2002, respondent determined a deficiency and
issued separate notices of deficiency to petitioners. The
2Mr. Carter also testified to working nights in some
capacity during the year in question and until a few weeks before
trial, when he began receiving disability payments. He did not
specify the nature of his work. The deficiency assessed related
solely to the retirement benefits received from Kaiser Aluminum;
therefore, the nature of Mr. Carter’s other employment is
inconsequential.
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