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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 information
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Last modified: May 25, 2011