Ramzy M. and Lena Kopty - Page 2




                                         -2-                                          
                                             Additions to Tax/Penalties               
          Year           Deficiency          Sec. 6651(a)(1)   Sec. 6662(a)           
          1999           $94,699.32          $23,674.83     $12,793.13                
          2000           1,000.00            None                None                 
          Unless stated otherwise, all section references in this opinion             
          are to the Internal Revenue Code as in effect during the years in           
          issue.                                                                      
               The issues for decision are:  (1) Whether the distributions            
          received by petitioners during 1999 and 2000 from petitioner                
          Ramzy M. Kopty’s individual retirement account (IRA) in the                 
          aggregate amounts of $331,500 and $10,000, respectively, are                
          includable in petitioners’ gross income, pursuant to section                
          408(d); (2) whether petitioners are subject to the 10-percent               
          additional tax on early distributions imposed by section 72(t) on           
          the distributions received by petitioners from Mr. Kopty’s IRA              
          during 1999 and 2000; (3) whether petitioners are liable for the            
          addition to tax of $23,674.83 determined by respondent under                
          section 6651(a)(1) for failure to file a timely return for 1999;            
          and (4) whether petitioners are subject to the accuracy-related             
          penalty of $12,793.13 determined by respondent under section                
          6662(a) with respect to their 1999 return.                                  
                                  FINDINGS OF FACT                                    
               Petitioners are husband and wife.  They resided in Waterloo,           
          Belgium, at the time they filed their petition in this case.  In            








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