Janet A. Phillips - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WHERRY, Judge:  This case is before the Court on a petition            
          for redetermination of a $7,944 deficiency in Federal income tax            
          and additions to tax that respondent determined for petitioner’s            
          2004 taxable year.1  After concessions,2 the issues for decision            
               (1) Whether $52,327.73 in wage income and $430.84 (rounded             
          off by respondent to $430) in dividend income were includable in            
          petitioner’s 2004 taxable income;3                                          
               (2) whether petitioner is liable for an addition to tax of             
          $983.48 under section 6651(a)(1);4                                          

               1 Because $3,573.81 in Federal income tax had been withheld            
          from petitioner’s wages, her balance due was shown as $4,371, but           
          should be $4,370 on account of the dividend and withholding                 
               2 Respondent concedes that petitioner did not have $34 of              
          interest income as determined in the notice of deficiency.  In              
          addition, although, in the notice of deficiency, respondent                 
          determined an addition to tax pursuant to sec. 6651(a)(2),                  
          respondent now concedes that petitioner is not liable for an                
          addition to tax under sec. 6651(a)(2).                                      
               3 That $430.84 is comprised of $227.64 in dividends that               
          petitioner received under a stock purchase plan and $203.20 in              
          dividends that petitioner concedes she received as a registered             
          shareholder separate from her participation in the stock purchase           
               4 All section references are to the Internal Revenue Code of           
          1986, as amended and in effect for the taxable year at issue.               
          The Rule references are to the Tax Court Rules of Practice and              

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