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After concessions by respondent, the issues for decision are (1)
whether petitioner had unreported income in the amounts
determined by respondent, (2) whether petitioner is liable for a
10-percent additional tax on early distributions from her
individual retirement accounts (IRAs), (3) whether petitioner is
liable for the addition to tax determined by respondent under
section 6651(a)(1), and (4) whether the Court should impose a
penalty against petitioner pursuant to section 6673.
FINDINGS OF FACT
Some facts have been stipulated and are so found. When the
petition was filed, petitioner resided in Cobb, California.
In 1999, petitioner received gains of $16,194 from the sale
of securities through National Financial Services, gains of
$90,039 from the sale of securities through OppenheimerFunds
Services, income of $5,936 from the Social Security
Administration, dividends of $50 from National Financial
Services, dividends of $1,827 from OppenheimerFunds Services,
interest of $210 from the Rhode Island State Employees Credit
(...continued)
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure. Some dollar amounts have been
rounded.
Respondent stated in the explanation of income tax
examination changes attached to the notice of deficiency that
petitioner was liable for additions to tax of $27,321.30 for
failure to file under sec. 6651(a)(1) and $27,928.44 for failure
to pay tax under sec. 6651(a)(2), totaling $55,249.74.
Respondent concedes that petitioner is not liable for the
additions to tax under sec. 6651(a)(2).
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