- 6 -
respondent also determined that Mr. Bangs is liable for his
taxable year 2002 for the accuracy-related penalty under section
6662(a).
Mr. Platt and Ms. Platt timely filed Form 1040 for their
taxable year 2002.8 In that return, Ms. Platt did not include in
income the $8,803.879 that she received from Mr. Bangs during
2002.
On January 18, 2006, respondent issued to Ms. Platt a notice
of deficiency with respect to her taxable year 2002 (notice for
Ms. Platt’s taxable year 2002). In that notice, respondent
determined that Ms. Platt received $8,88310 of alimony that is
includible in her income for that year. In the notice for Ms.
Platt’s taxable year 2002, respondent also determined that Ms.
Platt is liable for her taxable year 2002 for the accuracy-
related penalty under section 6662(a).
OPINION
The parties submitted these cases fully stipulated under
Rule 122. That the parties submitted these cases under that Rule
does not affect who has the burden of proof or the effect of a
8For convenience, we shall generally refer hereinafter only
to Ms. Platt, and not to Mr. Platt.
9See supra note 5.
10See supra note 5.
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Last modified: March 27, 2008