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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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Last modified: May 25, 2011