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entered is not reviewable by any other court, and this opinion
shall not be treated as precedent for any other case.
Respondent determined for 2003 a deficiency in petitioner’s
Federal income tax of $26,416 and a section 6662(a) accuracy-
related penalty of $5,283.
After concessions,1 the issues for decision are: (1)
Whether petitioner failed to report as income a distribution from
an individual retirement account (IRA) in 2003, (2) whether
petitioner received cancellation of indebtedness income in 2003,
and (3) whether petitioner is liable for a section 6662(a)
accuracy-related penalty.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Boulder,
Colorado.
Petitioner and his spouse filed jointly for 2003, a Form
1040, U.S. Individual Income Tax Return.
1Respondent concedes that the distribution of $4,272 from
petitioner’s Medical Savings Account in 2003 is not includable as
income because petitioner substantiated that the distribution was
spent on medical expenses. Petitioner concedes that the
distribution of $22,000 from a traditional IRA managed by Gabelli
Asset Fund in 2003 is income. Petitioner also concedes that the
distribution of $22,000 is subject to a 10-percent additional tax
under sec. 72(t)(1) for early withdrawal.
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