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SADBERRY v. COMMISSIONER

Docket No. 10499-02.

87 T.C.M. 982 (2004)

T.C. Memo. 2004-40

Anthony J. and Denise D. Sadberry v. Commissioner.

United States Tax Court.

Filed February 18, 2004.

Attorney(s) appearing for the Case

Anthony J. and Denise D. Sadberry, pro se.

R. Scott Shieldes, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge.

Respondent determined a deficiency of $22,255 in petitioners' Federal income tax and a penalty of $4,433 under section 6662(a) for the year 1999.1

After a concession by petitioners,2 the issues for decision are: (1) Whether petitioners realized gross income under section 72 from two annuity distributions; (2) whether petitioners are liable...

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