Barbara E. Seaman - Page 10




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          accumulations).                                                             
               Petitioner timely filed a tax return for her taxable year              
          2003 (petitioner’s 2003 return).  In that return, petitioner did            
          not include in her gross income (1) the $13,809.35 that DFAS                
          showed as both “Gross distribution” and “Taxable amount” in                 
          petitioner’s 2003 Form 1099-R, (2) the $191.45 of 2003 interest             
          on petitioner’s Prudential policy dividend accumulations that               
          Prudential showed in petitioner’s 2003 Prudential Form 1099-INT,            
          and (3) the $435.87 of 2003 interest on petitioner’s USAA policy            
          dividend accumulations that USAA showed in petitioner’s 2003 USAA           
          Form 1099-INT.  In petitioner’s 2003 return, petitioner did not             
          claim as tax withheld the $1,354.71 that DFAS showed as “Federal            
          income tax withheld” in petitioner’s 2003 Form 1099-R.                      
               In the notice that respondent issued to petitioner for her             
          taxable year 2003, respondent determined, inter alia, to include            
          in petitioner’s gross income (1) the $13,809.35 that DFAS showed            
          as both “Gross distribution” and “Taxable amount” in petitioner’s           
          2003 Form 1099-R, (2) the $191.45 of 2003 interest on peti-                 
          tioner’s Prudential policy dividend accumulations that Prudential           
          showed in petitioner’s 2003 Prudential Form 1099-INT, and (3) the           
          $435.87 of 2003 interest on petitioner’s USAA policy dividend               
          accumulations that USAA showed in petitioner’s 2003 USAA Form               










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