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$7,178 was taxable, unemployment compensation of $4,403, total
income of $24,284.22, and adjusted gross income of $24,284.22.
Attached to petitioner’s 2002 return were, inter alia: (1) Form
CSA 1099R, Statement of Annuity Paid, for 2002 issued to peti-
tioner by OPM Retirement Programs that showed a gross annuity
amount of $7,178, tax withheld of $630, original contributions of
$4,110, and taxable annuity “UNKNOWN” and (2) Form 1099-R,
Distributions From Pensions, Annuities, Retirement or Profit-
Sharing Plans, IRAs, Insurance Contracts, etc., for 2002 issued
to petitioner by the Federal Thrift Savings Plan (TSP Form 1099-
R) that showed a gross distribution of $25,940.49, a taxable
amount of $25,940.49, and employee contributions or insurance
premiums of $0.
Respondent issued a notice of deficiency (notice) to peti-
tioner for his taxable year 2002. In the notice, respondent
determined for that year that petitioner must include in his
gross income $25,940.49, the total amount of petitioner’s loans,
that he is not entitled to the earned income tax credit, and that
he is liable for the accuracy-related penalty under section
6662(a).
Discussion
Although respondent must have commenced respondent’s exami-
nation of petitioner’s 2002 return after July 22, 1998, the
parties do not address section 7491(a). On the record before us,
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