- 2 - respondent orally moved to impose a $5,000 penalty pursuant to section 6673. After concessions, the issues for decision are: (1) Whether the pension distributions petitioner received during 2001 from the Defense Finance and Accounting Service and from the Thompson-Ramo-Wooldridge (TRW) pension plan are includable in income for 2001; and (2) whether the Court should impose a penalty pursuant to section 6673. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts, stipulation of settled issues, and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided in Apple Valley, California. Petitioner had been a reserve officer in the U.S. Air Force. During 2001, petitioner received $44,183 in retirement pension distributions from the Defense Finance and Accounting Service on account of his prior service as a reserve officer in the U.S. Air Force. Petitioner was not injured while serving in the U.S. Air Force, and the retirement pension distributions were paid for petitioner’s prior service in the U.S. Air Force and not on account of a disability. Petitioner had been an engineer for TRW. During 2001, petitioner received $3,040 in retirement pension distributions from the TRW pension plan.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007