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deficiency, respondent determined the following deficiencies and
additions to tax in petitioners’ Federal income taxes:
Michael Alan Jackson
Additions to tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
2000 $7,452 $1,382.25 n/a $283.92
2002 6,624 1,830.84 n/a 214.67
2003 5,466 1,503.15 n/a 141.04
Mary Joy Jackson
Additions to tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
2000 $4,675 $184.00 n/a n/a
2003 1,821 409.73 $100.16 n/a
The issues for decision are: (1) Whether petitioners
received taxable income in the amounts respondent determined;
(2) whether petitioners are entitled to deductions; (3) whether
Michael Alan Jackson (Mr. Jackson) is liable for a 10-percent
additional tax under section 72(t)(1); and (4) whether
petitioners are liable for the additions to tax that respondent
determined in the respective notices of deficiency.2
Background
When they filed their petition regarding their 2000 taxable
year, petitioners resided in Simpsonville, South Carolina. When
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code), as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007