Richard and Arline Muller - Page 3
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Respondent determined a $12,567 deficiency in petitioners’
2003 Federal income tax and a $2,513 accuracy-related penalty
under section 6662(a). The issues for decision are:
(1) Whether a distribution from an individual retirement account
(IRA) is includable in petitioners’ 2003 income; and (2) whether
petitioners are liable for the accuracy-related penalty.
Some of the facts have been stipulated and are so found.
Petitioners are and were at all times relevant married to each
other. Their joint 2003 Federal income tax return was timely
filed. References to petitioner are to Richard Muller.
Petitioner, who was born in 1934, spent most of his working
career in the trucking industry. One of his former employers
went out of business during 2000. As a result, petitioner
received a $72,000 distribution from some type of employment-
based employee benefit plan. No portion of the $72,000
distribution was included in the income reported on petitioners’
2000 joint Federal income tax return. As best can be determined
from the record, at least a portion of the $72,000 distribution
made its way into an individual retirement account that
petitioner maintained with Commerce Bank.
The total value of the IRA as of January 1, 2003, was
$47,860.49. Three interest accruals totaling $595.62 added to
the balance of the IRA during 2003; otherwise there were no
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Last modified: March 27, 2008