- 19 - the record before us, we find that respondent has satisfied respondent’s burden of production under section 7491(c) with respect to the accuracy-related penalty. In support of her position that she is not liable for the accuracy-related penalty under section 6662(a), petitioner claimed at trial12 that she never received: (1) The separate Sun Life Forms 1099-R showing the gross distributions made by Sun Life during 2001 of $25,940 and $170,429 with respect to dece- dent’s fixed annuity contract and decedent’s fixed/variable annuity contract, respectively; (2) the separate A.G. Edwards Forms 1099-R showing the gross distributions made by A.G. Edwards during 2001 totaling $8,500 and $10,200 from decedent’s IRA and petitioner’s IRA, respectively; and (3) the separate Forms 1099 showing the distributions made by American General during 2001 of $400 of interest income and $1,365 of other income, respectively. In further support of her position that she is not liable for the accuracy-related penalty under section 6662(a), peti- tioner claimed at trial that she believed that the respective gross distributions of $25,940 and $170,429 made by Sun Life during 2001 with respect to decedent’s annuity contracts and the respective gross distributions of $8,500 and $10,200 made by A.G. 12At the conclusion of the trial in this case, the Court directed the parties to file simultaneous opening briefs and simultaneous answering briefs. However, petitioner filed a notice of intent not to file posttrial briefs.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011