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After concessions,2 the issues for decision are: (1)
Whether petitioner must include wages of $1,076 in her gross
income; (2) whether she must include individual retirement
account (IRA) distributions of $14,010 in her gross income; (3)
whether she is liable for an addition to tax under section
6651(a)(1) of $344; (4) whether section 6501(a) bars respondent
from assessing any tax due; and (5) whether petitioner is
entitled to reasonable litigation costs.
FINDINGS OF FACT
Petitioner resided in a State within the jurisdiction of the
Court of Appeals for the Ninth Circuit when she filed her
petition.
During 1996, petitioner worked for a public school district
and received wage income of $1,076.
Petitioner had three IRAs during 1996, one account with T.
Rowe Price (the T. Rowe Price IRA) and two accounts with the
Lindner Growth Fund administered by Star Bank (the first Star
Bank IRA and the second Star Bank IRA, respectively). On
February 26, 1996, petitioner received a $7,000 distribution from
1(...continued)
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure. Amounts are rounded to the nearest
dollar.
2 Respondent concedes that petitioner is not liable for an
addition to tax under sec. 6651(a)(2) and, as a result, seeks to
increase the addition to tax under sec. 6651(a)(1) to $344.
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