- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 Next
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