Respondent determined a deficiency in petitioner's Federal
income tax for the taxable year 1990 in the amount of $4,047.
The deficiency includes the 10-percent additional tax imposed by
section 72(t) on early distributions from qualified retirement
plans.
After a concession by petitioner,2 the issues for decision
are as follows:
(1) Whether petitioner received unreported wages in the
amount of $10,899; and
(2) whether petitioner is liable for the additional tax
imposed by section 72(t).
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in the State of New York at the time
that his petition was filed with the Court.
Petitioner's Employment
In June 1989, petitioner signed a 5-year contract with the
Poughkeepsie City School District (the school district) to serve
as assistant superintendent. In September 1989, petitioner was
2 In the notice of deficiency, respondent determined that
petitioner failed to report a distribution from American Capital
Trust Co. in the amount of $2,410.91. Petitioner did not raise
this issue in his pleadings, nor did he address it at trial.
Accordingly, this issue is deemed to be conceded by petitioner.
Rules 34(b)(4), 142(a).
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