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Subsequent to mailing the April 5 letter, respondent
discovered what was believed to be a second error. Petitioners
claimed total income tax withholding of $6,682.75 on their 2002
return. Respondent reduced this amount by $752 to reflect income
tax withheld on a pension plan distributed from Christ Hospital
to petitioner Alfreda Kocot. This reduction occurred as a result
of petitioners’ erroneous attachment of Forms 1099-R,
Distribution from Pensions, Annuities, Retirement or Profit-
Sharing Plans, IRAs, Insurance Contracts, etc., for both taxable
years 2001 and 2002 to their 2002 return. Although the $752
reduction was reflected on the April 5 letter, correspondence
between the parties subsequently resolved this discrepancy.
On June 14, 2004 (June 14 letter), respondent sent a third
revised proposed change letter that restored petitioners’ total
claimed income tax withholding to $6,682.75, yet kept the amount
of taxable Social Security benefits received at $24,329. As a
result of these changes, the June 14 letter computed an income
tax deficiency of $986.
Respondent issued a notice of deficiency in the amount of
$986 on August 30, 2004. Petitioners paid the deficiency on
October 4, 2004, and interest thereon on January 3, 2005.
Petitioners timely filed their petition in the underlying case on
November 22, 2004.
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Last modified: May 25, 2011