- 21 - an annuity, including a retirement plan, where an exception does not apply. Sec. 72(a). Additionally, unless an exception applies, there is a 10-percent additional tax on early withdrawals from qualified retirement plans. Sec. 72(t)(1). The Michoff, Srs., have offered no testimonial or documentary evidence to contradict their stipulations or to support an exclusion. Respondent's determination is therefore sustained on this issue. Unreported Income--Michoff, Srs. Revenue Agent Anita Russell, using a bank deposits analysis, determined that the Michoff, Srs., received unreported taxable income in the 1986, 1987, 1988, and 1989 tax years. Based on this analysis, respondent, after concessions, argues that the Michoff, Srs., had unreported income for those years in issue in the amounts of $75,740, $10,107, $10673, and $4,600, respectively. The Michoff, Srs., purchased a cashier's check from El Dorado Savings and Loan Association for the purpose of purchasing real property in the amount of $64,500 in the 1986 tax year. The Michoff, Srs., made deposits in the amounts of $11,240 and $10,107 which are in issue to their El Dorado Savings and Loan Association account in the 1986 and 1987 tax years, respectively. These deposits do not make up the total amount deposited into this account in these years.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011