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under section 6662(a)1 for 2001. After concessions,2 we must
decide two issues. The first issue is whether petitioner should
have included a $160,000 payment she received from her employer,
Power Conversion, Inc. (PCI), in her taxable income for 2001. We
hold that petitioner should have included this payment in her
taxable income.3 The second issue is whether petitioner is
liable for the accuracy-related penalty under section 6662(a).
We hold that she is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioner resided in Washington
at the time her petition was filed.
Petitioner’s Employment
The dispute here focuses upon whether the $160,000
petitioner received from PCI was a gift or taxable income. PCI
employed approximately 60 people and manufactured electronic
components, magnetic coil, and transformers used by other
1All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2The parties have resolved all other issues raised in the
deficiency notice and the petition.
3We note that the parties stipulated that petitioner would
not be liable for self-employment tax if the Court determined
that the payment was income.
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