- 2 -
Respondent determined a deficiency of $1,226 and an
accuracy-related penalty under section 6662(a) of $245 in
petitioners’ 2000 Federal income tax.
After a concession by respondent,2 the issues are (1)
whether petitioners3 are entitled to exclude from gross income
payments made by the County of Baltimore, Maryland, pursuant to
provisions of the Employees’ Retirement System of Baltimore
County (ERS), (2) whether petitioners overstated Catherine E.
France’s wages by $737 on their 2000 Federal income tax return,
and (3) whether we have jurisdiction over a deficiency in
petitioners’ 1997 income tax.4
The findings of fact and conclusions relevant to each issue
are summarized below. Petitioners resided in Finksburg,
Maryland, at the time their petition was filed.
2 Respondent concedes that petitioners are not liable for
the accuracy-related penalty under sec. 6662(a) for taxable year
2000.
3 Petitioner Catherine E. France did not appear at the
trial and did not execute the stipulation of facts. With respect
to her, we will dismiss this case for failure to prosecute. See
Rule 123(b). The decision, when entered, will be in the same
amount as ultimately determined against petitioner Larry J.
France. In the opinion, references to petitioner are to Larry J.
France.
4 Respondent also made a computational adjustment to
petitioners’ taxable Social Security income for taxable year 2000
based on the proposed increase to petitioners’ taxable income.
Resolution of this issue will depend on our decision regarding
petitioners’ gross income for taxable year 2000.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011