Bidyut K. Bhattacharyya and Diana T. Bhattacharyya - Page 2

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          to tax under section 6651(a)(1) of $38,837.1  After concessions,2           
          the issues for decision are:  (1) Whether respondent’s and                  
          petitioners’ motions to conform pleadings to the evidence should            
          be granted; (2) whether petitioners received but failed to report           
          certain items of income; (3) whether petitioners are liable for a           
          10-percent additional tax under section 72(t) on early                      
          distributions from qualified retirement plans; (4) whether                  
          petitioners are entitled to certain itemized deductions; (5)                
          whether petitioners are liable for any alternative minimum tax;             
          and (6) whether petitioners are liable for an addition to tax               
          under section 6651(a)(1).                                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, supplemental stipulation of facts, and            
          the second supplemental stipulation of facts and attached                   
          exhibits are incorporated herein by this reference.  At the time            
          they filed their petition, petitioners resided in Beaverton,                
          Oregon.                                                                     



               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.  All                  
          amounts are rounded to the nearest dollar.                                  
               2  The parties have agreed to certain issues, either in the            
          stipulation of facts, at trial, or on brief, and respondent has             
          conceded other issues.  The parties’ agreements and concessions             
          are discussed herein.                                                       




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