Robert J. Geiger - Page 2




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               In a notice of deficiency issued to petitioner on November              
          20, 1996, respondent determined a deficiency in his 1992 Federal             
          income tax in the amount of $1,951, and an addition to tax under             
          section 6651(a)(1) in the amount of $488.                                    
               The issues for decision are:  (1) Whether various items of              
          income attributed to petitioner in the notice of deficiency must             
          be included in his 1992 income; (2) whether petitioner is liable             
          for the 10-percent additional tax imposed by section 72(t) with              
          respect to a distribution from a qualified retirement plan; (3)              
          whether petitioner, who did not file a 1992 Federal income tax               
          return, is liable for the addition to tax under section                      
          6651(a)(1) for his failure to do so; and (4) whether a penalty               
          under section 6673(a) should be imposed upon petitioner.                     
                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.                
          Petitioner was born on July 16, 1947.  He was 45 years old and               
          married as of the close of 1992.  He resided in Bethlehem,                   
          Pennsylvania, at the time the petition was filed.                            
               Petitioner graduated from Wittenberg University in 1970.  He            
          majored in business administration, a curriculum that included               
          accounting courses.  Apparently, after graduating from college,              
          petitioner served in the U.S. Army for a period of time.                     
               In 1972 petitioner began working for Geiger's Beverage,                 
          Incorporated (Geiger's), a family owned corporation engaged in               
          the business of malt beverage distribution.  Petitioner was                  
          employed by Geiger's from 1972 until 1987 or 1988.  During some              

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