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Respondent's Deficiency Determination For 1990
In the notice of deficiency for 1990, respondent determined
that petitioners are liable for: (1) The additional tax under
section 72(t) for a premature distribution from petitioner's IRA
with First National, and (2) the excise tax under section 4980A
for an excess distribution from such IRA.13
Respondent's Claim For An Increased Deficiency For 1990
In her amended answer, respondent asserted deficiencies in
petitioners' income tax and excise tax under section 4980A for
the taxable year 1990 in the total amount of $19,394, an increase
of $3,725 over the total determined in the notice of
deficiency.14 The increase is principally attributable to the
fact that petitioner withdrew $157,174 from his IRA with First
National in 1990 but only reported $150,000 thereof on his 1990
income tax return. Correlative adjustments were asserted
regarding the additional tax under section 72(t) and the excise
tax under section 4980A.15
13 See supra note 6 regarding respondent's concession of the
excise tax as to petitioner Patricia M. Brown.
14 See supra note 5 for a breakdown of the increase by the
type of tax involved.
15 Other adjustments asserted by respondent that served to
increase petitioners' income tax include: (1) The understatement
of interest income in the amount of $512, (2) the overstatement
of a deduction for mortgage interest in the amount of $2,218, and
(3) the understatement of additional income from Maryland State
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