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1. Held: R’s adjustments to income and disallowance
of deductions and dependency exemptions claimed by P are
sustained.
2. Held, further, R’s imposition of the 10-percent
additional tax under sec. 72(t)(1), I.R.C., is sustained.
3. Held, further, R’s imposition of additions to tax
under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C., are
sustained. P’s 1988 return, filed more than 2 years after
R’s issuance of the notice of deficiency, is disregarded for
purposes of computing the “required annual payment” under
sec. 6654(d)(1)(B)(i), I.R.C.
Fortunato J. Mendes, pro se.
Wilton A. Baker, for respondent.
HALPERN, Judge: By notice of deficiency dated May 3, 1995
(the notice), respondent determined a deficiency in and additions
to petitioner’s Federal income tax for calendar year 1988
(sometimes, the audit year) as follows:
Additions to Tax
Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6654
$8,487 $2,122 $424 $484
The adjustments giving rise to the deficiency are
respondent’s inclusion in income of amounts reported on
information returns as having been paid to petitioner during 1988
(sometimes, the income items), and his imposition of the
10-percent additional tax on early distributions from qualified
retirement plans, offset by his allowance of the standard
deduction and one personal exemption. In addition, respondent
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