-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 (...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).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011