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Petitioner Steven Rudolph Kaldi filed a petition with this
Court in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 for 2002.
Pursuant to section 6330(d), petitioner seeks review of
respondent’s determination.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioner resided
in Las Vegas, Nevada.
Petitioner, an insurance agent, filed his Form 1040, U.S.
Individual Income Tax Return, for the taxable year 2002 on July
14, 2004, showing an underpayment of income tax.2 The source of
the underpayment was a $45,000 distribution from a qualified
retirement account.3 He included the $45,000 in his gross income
for 2002 and reported the corresponding additional early
withdrawal tax of $4,500 under section 72(t).
Petitioner gave $20,000 of the distribution to his daughter,
and put the remaining $25,000 into an investment account managed
2 Petitioner had the return prepared by an accountant who
had been preparing his taxes since 1980.
3 Petitioner received a distribution of $117,552 from a
qualified retirement account and properly rolled over all but
$45,000 of that amount into another qualified retirement account.
Petitioner was 57 years of age at the time of the distribution.
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