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section 6654(a) in the amounts of $3,081.80 and $790.55,
respectively.
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(1) Whether funds withdrawn by petitioner from a qualified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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