David W. Chiu - Page 2

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            section 6654(a) in the amounts of $3,081.80 and $790.55,                                     
                  After concessions, the issues for decision are as follows:                             
            (1) Whether funds withdrawn by petitioner from a qualified                                   
            individual retirement account (IRA) are includable in his gross                              
            income, and if so, whether petitioner is subject to a 10-percent                             
            additional tax on early distributions under section 72(t).  We                               
            hold that the funds are includable and that petitioner is subject                            
            to the 10-percent additional tax under section 72(t).                                        
            (2) Whether petitioner is allowed deductions for moving expenses,                            
            real estate taxes, home mortgage interest, charitable                                        
            contributions, and trade or business expenditures.  We hold that                             
            petitioner has substantiated the deduction for home mortgage                                 
            interest in the amount of $7,414.77.  We hold that the remainder                             
            of the aforementioned deductions are not allowed.  (3) Whether                               
            petitioner is liable for an addition to tax for failure to timely                            
            file his 1990 Federal income tax return under section 6651(a)(1).                            
            We hold that he is. (4) Whether petitioner is liable for an                                  
            addition to tax for failure to pay estimated income tax under                                
            section 6654(a).  We hold that he is.                                                        
                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.  We                           
            incorporate by this reference the stipulation of facts and                                   

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