- 2 - OPINION OF THE SPECIAL TRIAL JUDGE DEAN, Special Trial Judge: For the 1990 taxable year, respondent determined a deficiency in petitioner's Federal income tax in the amount of $8,777 (which included additional tax under section 72(t) in the amount of $239) and additions to tax under section 6651 in the amount of $1,724.75 and under section 6654 in the amount of $440.14. The parties have resolved all issues resulting from adjustments in the notice of deficiency except for the following: (1) Whether three payments received by petitioner in 1990 are taxable to petitioner in the amounts determined by respondent; (2) whether petitioner is liable for additional tax on early retirement distributions under section 72(t); and (3) whether petitioner is liable for additions to tax under sections 6651 and 6654. Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Omaha, Nebraska, at the time he filed his petition. Background Petitioner did not timely file a 1990 Federal income tax return. Respondent issued a notice of deficiency to petitioner on March 15, 1993. Respondent had received information returns from several payors indicating that payments had been made to petitioner during 1990. Respondent used these informationPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011