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under section 6651(a) in the amount of $674 and under section
6654(a) in the amount of $91.
The issues for decision are: (1) Whether certain payments
received by petitioner during 1992 are includable in his gross
income; (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 exhibits received into evidence
are incorporated herein by reference. Petitioner resided in
Altamonte Springs, Florida, at the time he filed his petition.
FINDINGS OF FACT
For the 1990 and 1991 tax years, petitioner filed Forms 1040
which he signed without altering the jurat. For the 1992 tax
year, however, petitioner filed a Form 1040NR (U.S. Nonresident
Alien Income Tax Return) dated June 15, 1993, which was received
by respondent on June 22, 1993. On this return petitioner
reported that he was a citizen of the country of "Florida,
America". Petitioner claimed "other single nonresident alien"
filing status. After reported estimated tax payments, Federal
income tax withheld, and excess Social Security tax withheld,
petitioner claimed a tax refund of $9,707. The only income
petitioner reported was $7,537 of unemployment compensation.
Petitioner altered the jurat on the 1040NR form by adding the
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