- NEXTRECORD -
Petitioner filed a Federal income tax return (Form 1040) for
1990. On his return, petitioner computed his tax liability using
the cash receipts and disbursements method of accounting.
Petitioner received a Form W-2 from the school district
disclosing the payment of wages in 1990 in the amount of
$66,254.66. Petitioner did not attach such form to his return.
Rather, he attached Form 4852 (Substitute for Form W-2). On such
form, as well as on the return itself, petitioner reported wages
in the amount of $55,355.76; i.e., $66,254.66 less net wages
withheld in the amount of $10,898.90.
Petitioner did not report the distribution from his American
Capital account on his return for 1990.
Respondent's Notice of Deficiency
In the notice of deficiency, respondent determined that
petitioner failed to report wages in the amount of $10,899.
Respondent also determined that the distribution from
petitioner's American Capital account was includable in
petitioner's gross income.5 As a corollary, respondent
determined that petitioner was liable for the 10-percent
additional tax imposed by section 72(t).
OPINION
The issues for decision are whether petitioner failed to
report wages in the amount of $10,899 and whether petitioner is
5 See supra note 2 regarding petitioner's concession related
to this distribution.
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Last modified: May 25, 2011