Richard Mark Hilton - Page 4




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               On May 28, 2003, petitioner received a distribution of                 
          $50,000 from a traditional IRA managed by Franklin Templeton Bank           
          & Trust (distribution).  On October 24, 2003, petitioner                    
          deposited approximately $41,000 of the $50,000 May distribution             
          back into the same Franklin Templeton account.  Petitioner did              
          not include any of the distribution as income on the return.                
               In 2003, petitioner had $2,136 of debt canceled by American            
          Express Centurion Bank (American Express).  Petitioner did not              
          include the amount of the canceled debt as income on the return.            
               Respondent subsequently issued to petitioner and his spouse            
          a statutory notice of deficiency for 2003, determining that they            
          failed to include in their income the distribution and the amount           
          of the canceled debt.  Respondent also determined that the                  
          distribution was subject to a 10-percent additional tax under               
          section 72(t) for early withdrawal.  Respondent indicated on the            
          deficiency notice that the proposed changes to income would                 
          reduce the amount of itemized deductions on Schedule A, Itemized            
          Deductions, and the claimed child tax credits.                              

















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