- 2 - 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 fromPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011