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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
are:
(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
rounding.
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
plan.
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
Procedure.
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Last modified: March 27, 2008