Robert J. Dwyer and Catherine Dwyer, pro se.
Andrew J. Mandell, for respondent.
NIMS, Judge: For the year 1989, respondent determined the
following deficiency in petitioners' Federal income tax and
penalties:
Addition to Tax Penalty
Deficiency Sec. 6651(a)(1) Sec. 6662(a)
$79,092 $19,773 $15,818
Unless otherwise stated, all section references are to
sections of the Internal Revenue Code in effect for the year
1989, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions, the only issue remaining for decision is
whether petitioners are liable under section 72(t) for the 10-
percent additional tax on an early distribution from a qualified
retirement plan.
FINDINGS OF FACT
Some of the facts were stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners resided in Remsenburg, New
York, when they filed their petition.
Robert J. Dwyer (petitioner or Robert) is a stock trader,
specializing in trading corporate stock on a short-term basis.
He was 53 years old in 1989.
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