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In the 2001 joint return, petitioner did not report interest
income of $400 and other income of $1,365 paid during 2001 by
American General. Nor did petitioner report in the 2001 joint
return the gross distributions of $25,940.28 and $170,429.52 paid
during 2001 by Sun Life with respect to decedent’s fixed annuity
contract and decedent’s fixed/variable annuity contract, respec-
tively. In addition, petitioner did not report in the 2001 joint
return the gross distributions of $8,500 and $10,200 made during
2001 by A.G. Edwards from decedent’s IRA and petitioner’s IRA,
respectively.
In the notice of deficiency (notice) that respondent issued
to petitioner for her taxable year 2001, respondent determined to
include in gross income for that year: (1) Interest income of
$400 paid by American General, (2) other income of $1,365 paid by
American General, (3) a gross distribution of $25,940 paid by Sun
Life with respect to decedent’s fixed annuity contract, (4) a
gross distribution of $170,429 paid by Sun Life with respect to
decedent’s fixed/variable annuity contract, and (5) gross distri-
butions of $10,200 made by A.G. Edwards from petitioner’s IRA.7
Respondent also determined in the notice that petitioner is
7Respondent indicated in the notice that petitioner did not
report in the 2001 joint return gross distributions of $8,500
made by A.G. Edwards during that year from decedent’s IRA.
Respondent failed to include in the computation of the $66,497
deficiency determined in the notice those unreported gross
distributions. See infra note 10.
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