- 2 - $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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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