Dwight S. & Antonina K. Platt - Page 6




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          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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