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).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011