Robert J. Geiger - Page 4




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               During 1992, petitioner maintained an interest bearing                  
          checking account at the First Valley Bank.  For years prior to               
          the year in issue, he received refunds of Federal income taxes,              
          sometimes amounting to thousands of dollars.                                 
               Respondent's Information Return Master File (IRMF)                      
          transcript indicates that several payors issued information                  
          returns to petitioner for the taxable year 1992 as follows:                  
                                                Type of                                
              Payor                  Form       income            Amount               
              Geiger's Bvgs., Inc. 1099B        S-T cap. gains   $15,282               
              First Valley Bank      1099-INT   Interest              34               
              U.S. Treasury Dept.    1099-INT   Interest              16               
              Manufacturer's Life    1099R      Taxable distr.     1,771               

               In the notice of deficiency issued to petitioner on November            
          20, 1996, respondent determined that petitioner must include the             
          above items of income (the items of income) in his 1992 income.              
          In computing his 1992 taxable income, respondent took the items              
          of income into account and allowed petitioner a personal                     
          exemption deduction and the standard deduction appropriate for a             
          married individual who files a separate return.  Petitioner's                
          1992 Federal income tax liability and the deficiency here in                 
          dispute were computed by application of the applicable rate of               
          Federal income tax to petitioner's taxable income and adding to              
          that amount the additional tax imposed by section 72(t) on the               
          distribution from Manufacturer's Life.  Respondent further                   
          determined that petitioner is liable for the addition to tax                 
          under section 6651(a) for his failure to file a 1992 Federal                 
          income tax return.                                                           

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