- 2 - Respondent determined deficiencies in petitioners’ Federal income taxes for the taxable years 1997 and 1998 in the amounts of $5,400 and $1,228, respectively.2 After a concession by respondent,3 the issue for decision is whether petitioners are liable under section 72(t) for the 10- percent additional tax on early distributions from qualified retirement plans. We hold that they are. Background Some of the facts have been stipulated, and they are so found. Petitioners resided in Chicago, Illinois, at the time that their petition was filed with the Court. Petitioner Mary G. Keeley (Mrs. Keeley) worked part-time for the West Chicago School District in 1997 for a time period not disclosed in the record. From the end of December 1997 to the present, Mrs. Keeley has been working for Tyndale House Publishers. Petitioner Brian P. Keeley (Mr. Keeley) worked as a leasing manager with Hughes Enterprises, a commercial laundry equipment distributor, for some time until August 1996. In August 1996, Mr. Keeley left Hughes Enterprises because he was dissatisfied with the annual reduction in his base salary and commission 2 All numbers are rounded to the nearest dollar. 3 At trial, respondent conceded the erroneous disallowance of a $400 child tax credit that petitioners claimed in 1998.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011