- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007