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Respondent determined an accuracy-related penalty under
section 6662(a) against petitioners for the taxable year 2001.
The sole issue for decision is whether petitioners are liable for
the penalty.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in Amelia Island, Florida.
Thomas J. Forristal (petitioner) was a practicing physician
in the Cincinnati, Ohio, metropolitan area for 35 years before he
retired in 2001. That year petitioner received a $23,800
distribution from a retirement account with UBS PaineWebber. UBS
PaineWebber issued petitioner a Form 1099-R, Distributions from
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc., which listed the $23,800 as a taxable
amount. Petitioner received the Form 1099-R in or about February
2002. Petitioners were in the process of moving to Florida at
that time.
Petitioners used an accounting firm in Cincinnati to prepare
their joint 2001 Federal income tax return. Petitioners provided
the accounting firm with information concerning their income for
that year, but they failed to provide the Form 1099-R. The
return prepared by the accounting firm omitted the $23,800 from
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