Susan F. Mostafa - Page 2

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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                   
               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           

          as amended, and all Rule references are to the Tax Court Rules of           
          Practice and Procedure.  Amounts are rounded to the nearest                 
               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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