Christina L. Belmont - Page 2




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               The issues for decision are:  (1) Whether petitioner                   
          received but did not report income from E.J. Famiano &                      
          Associates, Inc. (Famiano), of $5,924 and from Fidelity Services            
          Co. (Fidelity) of $18,239 during 2001; (2) whether petitioner is            
          liable for the additional tax under section 72(t) for early                 
          distributions from a retirement plan; (3) whether petitioner is             
          liable for additions to tax under sections 6651(a)(1)2 and 6654;            
          and (4) whether a section 6673(a) penalty should be imposed.3               
                                  FINDINGS OF FACT                                    
               Petitioner resided in Lakewood, Ohio, at the time the                  
          petition was filed.  Petitioner was born July 17, 1950.                     
               Petitioner filed joint Federal income tax returns with her             
          husband, Randy A. Belmont, for 1991 through 1998.  The tax                  
          returns were prepared by John D. Barber, a certified public                 
          accountant.  Petitioner testified that she filed a joint Federal            
          income tax return with her husband for 1999, but the return and             
          the identity of the preparer are not in the record.  Petitioner             


               1(...continued)                                                        
          the Internal Revenue Code (Code), as amended.  Amounts are                  
          rounded to the nearest dollar.                                              
               2Respondent has conceded the sec. 6651(a)(2) addition to tax           
          of $542.                                                                    
               3In the notice of deficiency respondent determined that                
          petitioner was entitled only to the standard deduction, one                 
          personal exemption, and tax rates applicable to a single                    
          individual.  Petitioner did not present any evidence or make any            
          arguments with respect to deductions, exemptions, or marital                
          status.  We conclude that she has abandoned any argument with               
          respect to these issues.                                                    





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