Scott A. Lewis - Page 2

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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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