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Respondent determined a deficiency of $10,824 in
petitioners' 2000 Federal income tax and the accuracy-related
penalty under section 6662(a) in the amount of $2,254. The
issues for decision are: (1) Whether petitioners are liable for
the 10-percent additional tax under section 72(t) for early
distributions from qualified retirement plans, and (2) whether
petitioners are liable for the section 6662(a) accuracy-related
penalty. At the time the petition was filed, petitioners were
legal residents of Dresden, Ohio.2
The facts are not in dispute. Jerome P. Reimann
(petitioner) is a metallurgical engineer and a "manager of
process improvement". Petitioner explained this latter category
as the review of reports from other engineers. He described his
occupation as being in "materials science". Petitioner has a
bachelor of science degree in science and metallurgical
engineering as a graduate of Wayne State University at Detroit,
Michigan. He received his degree in 1977, and his employment has
continuously been in that field of endeavor. In his career,
petitioner has been employed by several employers and has been a
participant in at least four pension plans qualified under
section 401(a).
2 Rule 91(a) requires that the parties stipulate all
facts, all documents and papers or contracts or aspects thereof,
and all evidence that should fairly not be in dispute.
Petitioners declined to agree to a written stipulation of facts.
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