Bradley D. Becnel - Page 3

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               Respondent determined a deficiency of $25,417 in                       
          petitioner’s Federal income tax for 2002 and an accuracy-related            
          penalty under section 6662(a) of $5,083.  Petitioner concedes the           
          deficiency but challenges the accuracy-related penalty.  The sole           
          issue, therefore, is whether petitioner is liable for the                   
          accuracy-related penalty under section 6662(a) for 2002.                    
               Some of the facts were stipulated, and those facts, with the           
          annexed exhibits, are so found and are incorporated herein by               
          reference.  Petitioner was a legal resident of the State of                 
          Louisiana at the time the petition was filed.                               
               A notice of deficiency was issued to petitioner for 2002               
          based upon his failure to include as income on his Federal income           
          tax return for that year payments that had been made to him by              
          four payors.  These payments had been reported as income to the             
          Internal Revenue Service on information returns.  Petitioner does           
          not challenge the payments as includable in gross income, the               
          amounts which were as follows:                                              

               Donaldson/Lufkin/Jenrette Securities         $75,711                   
               Hibernia National Bank                         5,000                   
               Ordinary dividends                               447                   
               Capital gain dividends                            98                   
          Total                                      $81,256                          

          Respondent also determined that petitioner is liable for an                 
          accuracy-related penalty of $5,083 under section 6662(a) for                







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