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SEWARDS v. COMMISSIONER

Docket No. 24080-08.

138 T.C. 320 (2012)

JAY SEWARDS AND FRANCES SEWARDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 2, 2012.

Attorney(s) appearing for the Case

Marshall West Taylor, for petitioners.

Scott B. Burkholder, for respondent.

OPINION

FOLEY, Judge:

The issues for decision, relating to petitioners' 2006 joint Federal income tax return, are whether petitioners may exclude certain retirement payments from income and whether petitioners are liable for a section 6662(a)1 accuracy-related penalty. The parties submitted this case fully stipulated pursuant to Rule 122.

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