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6651(a)(2).1 Following a trial that was held on September 11,
2006, we must decide (1) whether petitioner had unreported income
in the amounts determined by respondent, (2) whether petitioner
is liable for the 10-percent additional tax on early
distributions from his individual retirement account (IRA), (3)
whether petitioner is liable for the addition to tax determined
by respondent under section 6651(a)(1), (4) whether petitioner is
liable for the addition to tax determined by respondent under
section 6651(a)(2), (5) whether petitioner is liable for the
addition to tax determined by respondent under section 6654, and
(6) whether the Court should impose a penalty against petitioner
pursuant to section 6673.
FINDINGS OF FACT
Some of the facts of the case were stipulated and are so
found. When the petition was filed, petitioner resided in
Denver, Colorado.
Petitioner received a distribution of $43,331 from the
Public Employees Retirement Association in 2003, for which he was
issued a Form 1099 that listed $42,154 as taxable. Also in 2003,
petitioner received $24 of stock proceeds from United Shareholder
Services, Inc.
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Some dollar amounts have been rounded.
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