William C. Reichenbach - Page 3

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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             
               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                

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