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the first Star Bank IRA. On April 30, 1996, petitioner made a
$7,000 contribution to the second Star Bank IRA. On June 17,
1996, petitioner received a $7,010 distribution from the second
Star Bank IRA. Petitioner did not have any tax withheld from the
IRA distributions.
Petitioner did not file a Federal income tax return for
1996. On February 8, 1999, petitioner attempted to file a return
for 1996 and elected married filing jointly status. However,
respondent did not process the return because it was not signed
by petitioner’s husband.
On April 26, 2004, respondent sent petitioner a notice of
deficiency covering her 1996 taxable year. Using information
received from third parties, respondent determined that
petitioner was required to include in gross income wages of
$1,076 from the public school district and IRA distributions of
$14,010 from Star Bank. Respondent allowed petitioner a personal
exemption of $2,550 and a standard deduction of $3,350, and
determined a corresponding income tax deficiency of $1,377.
Respondent also determined that petitioner was liable for
additions to tax of $310 and $344 under section 6651(a)(1) and
(2), respectively.3
On June 19, 2004, petitioner filed a petition with this
3 Respondent concedes petitioner is not liable for the sec.
6651(a)(2) addition to tax. See supra note 2.
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