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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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Last modified: May 25, 2011