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All Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency in petitioner's 1994
Federal income tax in the amount of $6,336 and an accuracy-
related penalty under section 6662(a) in the amount of $1,267.
Following concessions made by both parties,1 the issues for
decision are: (1) Whether petitioner is subject to the 10-
percent additional tax on early distributions from qualified
retirement plans imposed by section 72(t); and (2) whether
petitioner is liable for the accuracy-related penalty under
section 6662.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
North Bend, Washington, when the petition in this case was filed.
Throughout the year in issue petitioner worked for Key
Trucking, Inc. (Key), as a salesman. At the beginning of 1994
petitioner was paid a salary by Key. In late January or early
February, Key ceased paying petitioner a salary, and, instead,
1 Petitioner conceded that he failed to report $15,540 of
compensation paid to him by Key Trucking, Inc. (Key). Petitioner
also conceded that $674 he received from Mac Transportation and
$1,008 he received from Atlantic and Pacific Freightways was
unreported nonemployee compensation and subject to self-
employment tax. Respondent conceded that commission income
petitioner received from Key in the amount of $15,540 was not
subject to self-employment tax.
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Last modified: May 25, 2011