Thomas Joseph and Judith Jane Forristal - Page 3

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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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