Jeffery Allen Robinson - Page 2

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          early distributions from qualified retirement plans under section           
          72(t).                                                                      
          The issues for decision are:  (1) Whether petitioner failed                 
          to report wage income of $1,179 in 1992; (2) whether petitioner             
          failed to report interest income of $28 in 1992; (3) whether a              
          lump-sum payment of $4,822 received during 1992 by petitioner               
          from a qualified employee retirement plan maintained by the                 
          Greater Columbus Convention Center (the convention center) is               
          includable in gross income in the year of distribution; and (4)             
          whether petitioner is liable for the 10-percent additional tax on           
          early distributions from qualified retirement plans under section           
          72(t).  The remaining adjustments in the notice of deficiency are           
          computational and will be resolved by the Court's holdings on the           
          aforementioned issues.2                                                     
          Some of the facts were stipulated, and those facts, with the                
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioner's                
          legal residence was Columbus, Ohio.                                         
          During the year at issue, petitioner was employed by the                    
          convention center as a crew foreman.  Petitioner had been                   
          employed by the convention center for approximately 10 years when           


          2     Respondent determined a reduction of $682 in the earned               
          income credit claimed by petitioner.  Further, respondent allowed           
          petitioner an additional withholding credit of $25 representing             
          taxes withheld on the $1,179 unreported wage income.                        




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