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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Lake, Michigan, when he petitioned the Court.
During 1993 and 1994, petitioner was employed by and
received wages from General Motors Corp. totaling $69,805 and
$33,183, respectively. On September 16, 1993, petitioner sold
property located in Essexville, Michigan, for $79,900.
Petitioner had purchased this property in or around 1962 for
$15,500. During 1994, petitioner received two distributions from
qualified retirement plans: $69,079 from his individual
retirement account maintained by Merrill Lynch, and $15,380 from
General Motors Hourly-Rate Employees' Pension Trust.1 During
1993 and 1994, petitioner did not file Federal income tax returns
or make any estimated tax payments; petitioner had $11,842 and
$6,603, respectively, in Federal income taxes withheld from his
wages.
Respondent determined that petitioner should have reported
income as follows: For 1993, $69,805 in wages and $73,140 in net
capital gains;2 for 1994, $33,183 in wages and $84,459 in taxable
1 At the end of 1994, petitioner was 58 years old. See
sec. 72(t)(2)(A)(i).
2 The notice of deficiency identifies petitioner's net
(continued...)
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