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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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