Anne C. Snyder - Page 2

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          $66,497 and $12,926, respectively.                                          
               In an amendment to answer, respondent asserted (1) an                  
          increase in (a) the deficiency in, and (b) the accuracy-related             
          penalty under section 6662(a) on, petitioner’s tax for her                  
          taxable year 2001 of $1,273 and $628, respectively, and (2) an              
          increased (a) deficiency in, and (b) accuracy-related penalty               
          under section 6662(a) on, petitioner’s tax for that year of                 
          $67,770 and $13,554, respectively.                                          
               The only issue remaining for decision is whether petitioner            
          is liable for her taxable year 2001 for the accuracy-related                
          penalty under section 6662(a).  We hold that she is.                        
                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.               
               Petitioner resided in Ellicott City, Maryland, at the time             
          she filed the petition.                                                     
               Petitioner, who attended three years of college where she              
          majored in education, and E. Bruce Snyder (decedent) were married           
          for about 38 years when he died after a long illness in May 2001.           
          During their marriage, decedent retained Robert Hopkins (Mr.                
          Hopkins) with A.G. Edwards & Sons, Inc. (A.G. Edwards) as their             
          financial advisor.                                                          
               With Mr. Hopkins’s assistance, in December 1994, decedent              
          and petitioner each opened an individual retirement account (IRA)           
          with A.G. Edwards.  Petitioner was the primary beneficiary of               






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