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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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Last modified: November 10, 2007