Robert J. Dwyer and Catherine Dwyer - Page 2

               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                 
                                       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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