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he left his position on September 26, 1992. As a result of his
termination of employment, petitioner received a lump-sum
distribution of the retirement benefits being held on his behalf
in the Greater Columbus Convention Center Benefit Plan.
Petitioner was thereafter employed by the K-Mart Corp. during
1992.
On his 1992 Federal income tax return, petitioner reported
taxable wage income from the convention center in the amount of
$10,980. In the notice of deficiency, respondent determined that
petitioner had unreported taxable wage income of $1,179,
unreported taxable interest income of $28, and unreported taxable
lump-sum pension income of $4,822, all based on information
reported to respondent by the respective payers. Also in the
notice of deficiency, respondent determined that petitioner was
liable for the 10-percent additional tax on an early distribution
from a qualified plan under section 72(t) in the amount of $482.
The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden is on the
taxpayer to prove that the determinations are in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Section 61 provides that gross income includes "all income
from whatever source derived" unless otherwise provided.
Furthermore, a taxpayer is required to maintain records
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