§66622

We hold that the distribution is includable in petitioner's gross income for 2009.

- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined a $7,411 deficiency in and a $1,457 penalty pursuant to section 66622 on petitioner’s 2000 Federal income tax.

In the Notice of Deficiency respondent determined the $2 million and $300,000 bequests were includible in decedent’s estate, an estate tax deficiency of $1,047,398 was due, and a section 66622 accuracy- related penalty of $184,000 applied.

324, 648–71.1 Pending before the Court is petitioner’s Motion for Partial Summary Judgment (Motion) seeking partial summary judgment that the accuracy-related penalty respondent determined under section 66622 is not assessable as a matter of law because of the application of the Seventh Amendment to the U.S.

He also determined accuracy-related penalties under section 66622 for those years of$230,115, $221,938, and $320,334, respectively.

MEMORANDUMFINDINGS OF FACT AND OPINION SWIFT, Judge: In these consolidated cases respondent determined deficiencies in petitioners' 2004joint Federal income taxes plus accuracy-related penalties under section 66622 as follows: Penalty Petitioners Deficiency Sec.

MEMORANDUMFINDINGS OF FACT AND OPINION SWIFT, Judge: In these consolidated cases respondent determined deficiencies in petitioners' 2004joint Federal income taxes plus accuracy-related penalties under section 66622 as follows: Penalty Petitioners Deficiency Sec.

SERVED Jun 08 2009 a 2 - Respondent determined deficiencies in Federal individual .,,,,income tax and an accuracy-related penalty under section 66622 against petitioners for 2003 as follows : Penalty Petitioner Deficiency Sec .

SERVED APR 2 9 2008 2 - Respondent determined a deficiency in Federal individual income tax and an accuracy-related penalty under section 66622 against petitioner for 2003 in the respective amounts of $12,470 and $2,494 .

GERBER, Judge: In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income tax and accuracy-related penalties under section 66622 for the 1992, 1993, and 1994 taxable years as follows: 2 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years under consideration, and Rule references are to the Tax Court Rules of Practice and Procedure.

Background--Procedure Respondent determined a deficiency in Federal corporate income tax against petitioner for 1990 in the amount of $33,208 and an addition to tax under section 66622 (negligence or substantial understatement of income tax) in the amount of $6,642.

66622 1985 $10,985 $549 $2,746 -- 1986 8,076 404 2,019 -- 1987 13,083 654 3,271 -- 1988 1,961 98 -- -- 1989 3,406 -- -- $578 1 Respondent determined that petitioner is liable for additions to tax for 1986 and 1987 under sec. 6653(a)(1)(A) and (B). 2 Respondent determined that petitioner is liable for negligence under sec. 6662(a), not substant