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CALLOWAY v. COMMISSIONER

Docket No. 8438-07.

135 T.C. 26 (2010)

LIZZIE W. AND ALBERT L. CALLOWAY, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 8, 2010.

Attorney(s) appearing for the Case

Brian G. Isaacson, for petitioners.

Daniel J. Parent, for respondent.

RUWE, Judge:

Respondent determined a $30,911 deficiency, a $6,583 addition to tax under section 6651(a)(1)1 for failure to timely file, and a $6,182.20 accuracy-related penalty under section 6662(a) in regard to petitioners' 2001 Federal income tax. The issues we must decide are: (1) Whether a transaction in which Albert L. Calloway (petitioner) transferred 990 shares of International Business Machines Corp. (IBM) common stock to...

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