Diana Cote - Page 2

          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               

          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.  Some dollar amounts have been             
               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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