Woodsum v. Comm'r
United States Tax Court
In 2006 Ps received gain of $3.4 million upon the termination of a "swap" transaction. P-H was personally involved in terminating the transaction and received from the payor a Form 1099-MISC, Miscellaneous Income, that reported the payment. Ps retained a firm with a lawyer and a certified public accountant to prepare their 2006 income tax return.
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In 2006 Ps received gain of $3.4 million upon the termination of a "swap" transaction. P-H was personally involved in terminating the transaction and received from the payor a Form 1099-MISC, Miscellaneous Income, that reported the payment. Ps retained a firm with a lawyer and a certified public accountant to prepare their 2006 income tax return. Ps gave to the firm all the 160-plus information returns they had received from third-party payors, including the Form 1099-MISC reporting the $3.4 million. The 115-page return that the firm prepared reported $29.2 million of adjusted gross income…
1Opinion of the Court
OPINION
GUSTAFSON, Judge:
This case is before the Court pursuant to section 6213(a)1 for redetermination of an accuracy-related penalty of $104,295 that the Internal Revenue Service (IRS) determined against petitioners Stephen G. Woodsum and Anne R. Lovett for tax year 2006, pursuant to section 6662(a). The issue for decision is whether petitioners had “reasonable cause” under section 6664(c)(1) for omitting $3.4 million of income from their joint 2006 Federal income tax return.
Background
The parties submitted this case fully stipulated, pursuant to Rule 122. We incorporate by this reference the…
2Cases cited7 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Metra Chem Corp. v. CommissionerUnited States Tax Court · 1987
- Magill v. CommissionerUnited States Tax Court · 1978
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