- 2 - distribution was subject to the 10-percent additional tax imposed by section 72(t). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioners resided in Houston, Texas, at the time they filed their petition. In 1976, petitioner opened an IRA as described in section 408(a). Petitioners made additional contributions to the IRA over the next several years. Petitioners claimed deductions on their Federal income tax returns under section 219 for all of their contributions to the IRA. Petitioners made no nondeductible contributions to the IRA. Petitioner was a civil engineer employed by the City of Houston, Texas, from May 6, 1985, until sometime in 1997. Petitioner was involuntarily demoted by the City of Houston effective December 3, 1996. The demotion resulted in a decrease of $11,700 to petitioner’s annual salary. In November 1997, petitioner began working full time for the City of Pearland, Texas. Because of financial hardship, in early 1997 petitioner requested a $6,000 distribution from the administrator of the IRA. Petitioner was 46 years old at the time he received thePage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011