-2- 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 thePage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011