- 2 - 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) forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011